For example, one California appellate court drew a new line after malicious prosecution claims found their way into California family law cases. See Bidna v. Rosen, 19 Cal. App. 4th 27, 23 Cal. Rptr.2d 251 (Cal. 4th Dist. 1993) (barring malicious prosecution actions for any family law motion or order

a malicious prosecution action by the disgruntled opposing litigant who was named as a party in that client's unsuccessful prior lawsuit."). 'The Bidna court's four reasons why malicious prosecution actions should be so barred in family law actions apply to all tort litigation in Florida: (1) there