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

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.