The Sixth Appellate District reversed an order of dismissal. The court held that a trial court abused its discretion in requiring vexatious litigants to furnish security in order to litigate a complaint where there was no showing that the litigants had no reasonable probability of prevailing on the merits.

In 2003, following repeated incidents in which developmentally disabled adult Nancy Golin was injured or wandered away from home, the probate court placed Nancy in permanent conservatorship in the custody of the State Department of Developmental Services (DDS), over the objections of her parents, Jeffrey and Elsie Golin.