EPF I – Does v Glass, lives on! 4th Amended Complaint Filed
A quick legal update for those who were following the path of the “Ex Post Facto I” complaint as it made it’s way from the District Court in 2018, to the 11th Circuit Court of Appeals, back to the District Court, only to be dismissed again…
A Fourth Amended Complaint was filed earlier this month and the FDLE is required to file its response to Plaintiff’s fourth amended complaint on or before May 27, 2026.
A copy of the complaint is below.
Does v Glass – 4th Amended Complaint
Just for reference, “Ex Post Facto II”, which was filed after EPF I, prevailed and it is the reason why we are able to report in state temporary travel online and why we are able to report vehicles online (instead of in person).
For further reference, we are currently working on a legal challenge to the recently enacted amendment to the registration statute which will hopefully incorporate an Ex Post Facto claim into it as well.
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This is the first time I’ve encountered the verbiage “irremediably depraved perverts” in a Federal court filing.
Notice how Val and Todd never give up!
Just a quick question. So is this 4th amended complaint just to force FDLE to allow out of state travel to reported via the online portal?
The 2026 Supreme Court decision in ***Ellingburg v. United States*** has handed the Florida Action Committee a massive victory in the fight against unconstitutional registry laws.
For too long, Florida has dodged the **Ex Post Facto Clause** by claiming the registry is just a “civil safety measure.” ***Ellingburg* just called their bluff.** The Supreme Court ruled that the government cannot avoid the Constitution simply by putting a “civil” label on what is clearly a punishment.
**Why this changes everything for our Ex Post Facto cases:**
* **Labels Don’t Matter:** If the Supreme Court says a financial payment is “punishment,” then a lifetime of reporting, GPS monitoring, and residency bans is definitely punishment.
* **End Retroactive Changes:** The Constitution forbids increasing a sentence after the fact. *Ellingburg* gives us the legal teeth to argue that Florida can no longer retroactively apply new, harsher rules to people whose cases are years or decades old.
* **The “Civil” Loophole is Closing:** This ruling signals that the highest court in the land is ready to strike down laws that use “public safety” as an excuse to ignore our fundamental rights.
The Florida Action Committee is ready to take this fight to the courts. If the state can’t retroactively change a fine, they shouldn’t be allowed to retroactively change your life. **The time to litigate is now.**
It is in litigation. The Ellingsburg decision was not about public safety. It was about restitution.
Gosh…. that’s disappointing. Thank you for the response!
What does in litigation mean?
When a legal matter is “in litigation,” it signifies that a formal dispute has entered the court system for resolution.
The Supreme Court did make something clear in Ellingburg v. United States (2026): courts must look at what a law actually does, not what it’s called. If it imposes ongoing, state-enforced burdens tied to a past conviction, it can qualify as punishment—even if labeled “civil.”
Florida’s registry laws require continuous reporting, restrict travel, and impose criminal penalties for noncompliance long after a sentence is complete. That looks more like ongoing punishment than regulation.
And in cases like mine in a federal possession of CP case, where no specific factual findings (such as victim age) were ever determined, the state is adding new consequences based on facts that were never adjudicated. That raises serious constitutional concerns.
Absolutely agree! We’ve posted some deep dives into this decision a few months ago and registry meets all the elements that Justice Thomas said constitute punishment.
Wait what?
We can report vehicle changes online?
Putnam county sent out letters stating that all vehicle changes must be done in person.
Please send us a copy of that letter IMMEDIATELY! [email protected]
I had to take ALL of my vacation to read this it was so long.
I hope whoever wrote this, has a long vacation coming up awards.
Hoping and praying that something gives and we can gain even a morsal of relief.
Most of our wins have been on ordinances, like Halloween restrictions or places we are not allowed, certain amounts of feet from.
Not sure how long this decision would take, but I know the Orginal does has been going on for like a million years. (Seems like it anyway)
I might be wrong. But I think since 2018. I was hoping for the Expost facto challenge. Probably will not be in my life time.