Florida Fish and Wildlife Conservation Commission v. Wakulla Fishermen's Association, etc., 141 So. 3d 723

Florida Fish and Wildlife Conservation Commission sought to enforce net restrictions under Art. X, §16 and related rules to ban gill/entangling nets and limit nearshore nets to 500 square feet mesh area.
Trial court held res judicata did not bar relitigation and enjoined enforcement of Art. X, §16 and related rules and the Commission’s rulemaking authority.
Appellees challenged the constitutionality of the rules facially and as applied to mullet fishermen; prior related proceedings and decisions were acknowledged.
The court of appeal held res judicata barred relitigation and reversed the injunctions and the authority to adopt rules, concluding the trial court erred.
The holding cites Wakulla Commercial Fishermen’s Association v. FWC, and prior Florida cases upholding the Net Limitation Amendment and related rules, as well as general res judicata doctrine.
The final disposition is REVERSED with the panel concurring

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether res judicata bars relitigation of the rules’ validity	Crum/Wakulla argued manifest injustice warrants relief	Commission contends prior adjudications foreclose relitigation	Yes; res judicata bars relitigation

Wakulla Commercial Fishermen’s Association, Inc. v. Florida Fish & Wildlife Conservation Comm’n, 951 So. 2d 8 (Fla. 1st DCA 2007) (relitigation barred; rational basis upheld rules as to mullet nets)
Crum v. Fla. Fish & Wildlife Conservation Comm’n, 888 So.2d 22 (Fla. 1st DCA 2004) (prior rulings support net limitation rules)
Fla. Dep’t of Transp. v. Juliano, 801 So.2d 101 (Fla. 2001) (four identities requirement for res judicata; §)
State v. McBride, 848 So.2d 287 (Fla. 2003) (res judicata applies to governmental actions)
Flagler v. Flagler, 94 So.2d 592 (Fla. 1957) (courts of equity cannot alter law or ignore established rules)