Commissioner Joe Carollo v. Platinum Advisors, LLC
A former consultant-turned-city commissioner was sued for breach of fiduciary duty, breach of contract, and trade secret misappropriation based solely on statements he made from the dais during a duly noticed City Commission agenda item concerning his ex-client's project. The Third District held that such conduct falls within absolute legislative immunity, regardless of alleged bad faith or unethical motive, and reversed the denial of his motion to dismiss with instructions to dismiss without prejudice.
Key facts
- Joe Carollo, a city commissioner and former consultant, was sued by his ex-client Platinum Advisors, LLC for breach of fiduciary duty, breach of contract, and trade secret misappropriation based on statements he made during a City Commission meeting.
- The plaintiff alleged that Carollo's statements from the dais during a duly noticed agenda item concerning the plaintiff's project constituted actionable conduct, despite Carollo's official legislative capacity.
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Why it matters
The opinion is a useful Third District statement that absolute legislative immunity shields local elected officials' statements and votes on agenda items even against private contract, fiduciary duty, and trade secret… — full analysis with a trial
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