In
Wittbold v. Miami-Dade County, (SD FL, June 27, 2013), a Florida federal district court dismissed a lawsuit claiming that the county, by limiting nude sunbathing to one fenced area of the 177 acre Haulover Beach Park, violated plaintiff's 1st Amendment right to practice his religion of Naturism as well as his due process rights. According to the court, plaintiff's complaint "is a cacophony of irrelevant facts, biblical quotations and personal opinions that fail to state any cause of action."