M.C. Dean, Inc. v. City of Miami Beach, Florida; and International Brotherhood of Electrical Workers, Local 349

2016 , Southern District of Florida

Judge Cecilia M. Altonaga

Summary

In the 2016 case, M.C. Dean, Inc. v. City of Miami Beach, Florida, United States District Judge Cecilia M. Altonaga dismissed the complaint against the City of Miami Beach and the International Brotherhood of Electrical Workers, Local 349, for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). M.C. Dean, an electrical design-build and systems integration firm, accused the defendants of misappropriating trade secrets after the City inadvertently disclosed unredacted payroll information to Local 349. This information, which M.C. Dean had provided to Clark Construction Group, LLC for the Miami Beach Convention Center renovation project, was claimed to be a trade secret due to efforts to maintain its secrecy and its economic value from not being generally known. The court, however, found that M.C. Dean did not adequately demonstrate it took reasonable steps to protect the trade secret or that misappropriation occurred, considering the contractual obligations to provide such information and the absence of restrictions on its use or disclosure. The decision underscores the necessity of clearly establishing and maintaining the confidentiality of information to claim trade secret protection under the DTSA and FUTSA. It also highlights the role of contractual agreements and public records laws in determining the status of alleged trade secrets. M.C. Dean was given a deadline to file an amended complaint, with the case facing dismissal with prejudice if not amended timely.