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Okaloosa Properties Management, LLC v. Hoffman, Larkin & Agnetti, P.A.

2026-08-26

Summary

Holding. The trial court erred in applying Florida's absolute litigation privilege to dismiss the claims because the allegations—involving private phone calls rather than statements before a judicial officer or filed court documents—failed to demonstrate that Agnetti's alleged acts occurred in the course of a judicial proceeding. The dismissal order is reversed and the case is remanded for further proceedings.

Okaloosa Properties Management sought damages against attorney John Bradley Agnetti and his law firm, alleging that Agnetti improperly persuaded the company's eminent domain counsel to treat a third party (Agnetti's client in an unrelated lawsuit) as the property owner instead of Okaloosa's actual owner. This allegedly caused Okaloosa to reject a favorable settlement offer. The trial court dismissed the claims based on Florida's absolute litigation privilege, reasoning that Agnetti's phone calls to the eminent domain counsel occurred during the course of pending litigation.

The appellate court reversed, holding that the absolute litigation privilege does not apply because the alleged wrongful conduct—phone calls made outside the courtroom and not filed with any court—did not occur "in the course of a judicial proceeding" as required by Florida law. The court reasoned that the privilege is intended to protect statements made before judicial officers or in court filings, where judges can remedy harm by striking improper statements or imposing contempt sanctions. Since private phone calls lack these judicial safeguards, they cannot qualify for absolute immunity even if they relate to pending litigation.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether private communications between attorneys constitute conduct occurring "in the course of a judicial proceeding" for purposes of the absolute litigation privilege
  • Proper scope and application of Florida's absolute litigation privilege to non-courtroom attorney conduct
  • Whether the absolute litigation privilege requires statements or acts to be before a judicial officer or filed with the court

Procedural posture

Okaloosa Properties Management appealed a trial court order granting Agnetti's motion to dismiss based on the absolute litigation privilege, which dismissed all claims with prejudice.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Third District Court of Appeal

State of Florida

Opinion filed August 26, 2026.

Not final until disposition of timely filed motion for rehearing.

No. 3D24-1502

Lower Tribunal No. 2024-002003-CA-01

Okaloosa Properties Management, LLC,

Appellant,

vs.

Hoffman, Larin & Agnetti, P.A., et al.,

Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Valerie R. Manno Schurr, Judge

Boyd Richards Parker & Colonnelli, P.L., and Marcus A. Nielsen, and Yvette R. Lavelle, for appellant.

Freeman Mathis & Gary, LLP, and Robert M. Klein and Christopher J. Fraga, for appellees.

Before FERNANDEZ, LOGUE, and GORDO, JJ.

LOGUE, J.

Okaloosa Properties Management, LLC (“Okaloosa LLC”) appeals a

final judgment dismissing with prejudice its claims against John Bradley

Agnetti and Hoffman, Larin & Agnetti, P.A. (collectively, “Agnetti”) for aiding

and abetting breach of fiduciary duty, tortious interference, and conspiracy.

It alleged that Agnetti, while representing a third party claiming an interest in

certain property owned by Okaloosa LLC, persuaded Okaloosa LLC’s

eminent domain attorney to treat the third party as Okaloosa LLC’s owner.

This allegedly caused Okaloosa LLC to lose a favorable settlement in certain

eminent domain negotiations. On appeal, Okaloosa LLC raises several

arguments, but only one merits discussion: whether Florida’s litigation

privilege provides absolute immunity for Agnetti’s alleged conduct. Because

the facts alleged in Okaloosa LLC’s operative complaint failed to show that

Agnetti’s alleged acts occurred in the course of a judicial proceeding, we

conclude the trial court erred in applying the absolute litigation privilege at

this stage and reverse and remand for further proceedings.

BACKGROUND

The following statement of facts is taken from the allegations in the

operative complaint. This case arises out of a dispute over property located

in Fort Walton Beach, Florida (the “Property”). Since 2010, Okaloosa LLC

has owned the Property. In May 2017, after learning the Florida Department

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of Transportation (“FDOT”) intended to acquire the Property through eminent

domain, Okaloosa LLC retained Joe Fixel and the Fixel Law Firm

(collectively, “Fixel”) to represent it in negotiations with FDOT. Fixel initially

kept Okaloosa LLC’s owner, Dror Levy, informed about the negotiations with

FDOT. But, as explained below, Agnetti ultimately persuaded Fixel to stop

informing and consulting Levy about the negotiations, which led to the lawsuit

at issue.

Allegations Regarding Miami Litigation

While the negotiations were ongoing, a separate case related to the

Property began. In January 2021, Levy’s former business partner Eliezer

Tabib and Levy’s former employer Marco Destin, Inc. (collectively, “Tabib”)

sued Levy in the Circuit Court for the Eleventh Judicial Circuit of Florida over

the ownership of the Property (the “Miami Litigation”). Tabib alleged Levy

took money from him to purchase the Property, then collected rent on the

Property without paying Tabib. Agnetti represented Tabib in that action.

At the outset of the Miami Litigation, Agnetti made telephone calls to

Fixel which are at issue in this case. Significantly, Agnetti and Fixel were not

opposing counsel in the same case. Fixel represented Okaloosa LLC in the

negotiations with FDOT over acquisition of the Property and Agnetti

represented Tabib in the Miami Litigation. During their phone calls, Agnetti

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persuaded Fixel to (1) treat Tabib as the owner of Okaloosa LLC; and (2)

consult only Tabib and not Levy regarding the negotiations with FDOT. As a

result, Fixel began to treat Tabib as the owner of Okaloosa LLC and provided

Tabib with updates regarding the FDOT negotiations instead of Levy,

Okaloosa LLC’s actual owner.

Allegations Regarding Eminent Domain Litigation

In February 2021, FDOT communicated a settlement offer of $889,000

for the Property to Fixel. On March 15, 2021, Fixel sent Tabib a letter

informing him of that offer. In that letter, Fixel referred to Tabib as the

president of Okaloosa LLC. Fixel then rejected FDOT’s settlement offer

without communicating the offer to Levy. As a result, on December 15, 2021,

a second case related to the Property began—FDOT sued Okaloosa LLC to

take the Property (the “Eminent Domain Litigation”).

In February 2022, Tabib’s attorney, Carlos Nunez, who served as

Agnetti’s co-counsel in the Miami Litigation, directed Fixel to inform Okaloosa

LLC of the state of the Eminent Domain Litigation. Fixel then informed

Okaloosa LLC, through Levy, of his rejection of the settlement offer, the

initiation of the Eminent Domain Litigation, his treatment of Tabib as the

owner of Okaloosa LLC, and his communications with Agnetti.

Subsequently, on March 14, 2022, Fixel withdrew as counsel for Okaloosa

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LLC in the Eminent Domain Litigation. Although Tabib filed a crossclaim and

third-party complaint in the Eminent Domain Litigation, Agnetti did not

represent Tabib in that case. As in the Miami Litigation, Tabib contested only

the ownership of the Property—not the ownership of Okaloosa LLC.

Proceedings Below

Consequently, Okaloosa LLC filed the underlying action in February

2024 against Agnetti, asserting claims of aiding and abetting breach of

fiduciary duty, tortious interference, and conspiracy. Okaloosa LLC based

these claims on Agnetti’s instructions (as Tabib’s lawyer) to Fixel to treat

Tabib instead of Levy as the owner of Okaloosa LLC and to freeze Levy out

of the negotiations with FDOT over its efforts to obtain the Property.

Okaloosa LLC’s complaint included references to the Miami Litigation

(between Tabib and Levy over ownership of the Property) and the Eminent

Domain Litigation (between FDOT and Okaloosa LLC over acquisition of the

Property with Tabib named as having a possible interest), including the case

name and number of both. Okaloosa LLC included those cases to

demonstrate that no party contested Okaloosa LLC’s ownership, only the

ownership of the Property.

After Okaloosa LLC filed its first amended complaint, Agnetti moved to

dismiss, arguing Florida’s absolute litigation privilege barred Okaloosa LLC’s

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three claims because Agnetti’s phone calls with Fixel occurred during the

Miami Litigation and the Eminent Domain Litigation. The trial court granted

Agnetti’s motion and dismissed the first amended complaint with prejudice.

It reasoned that Agnetti’s phone calls with Fixel had some relation to the

Miami Litigation or the Eminent Domain Litigation and occurred during the

course of one or both of those proceedings. Okaloosa LLC then filed a

motion for rehearing, which the trial court denied. This appeal followed.

ANALYSIS

I. Standard of Review

An order granting a motion to dismiss is reviewed de novo. Pacheco v.

Waldo Acebo, M.D., P.A., 406 So. 3d 319, 321 (Fla. 3d DCA 2025).

II. Absolute Litigation Privilege

Florida’s litigation privilege provides absolute immunity for any act that

(1) occurs during the course of a judicial proceeding; and (2) has some

relation to that proceeding. Levin, Middlebrooks, Mabie, Thomas, Mayes &

Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994). Absolute

privilege applies when these two requirements are met because “[i]n these

more formalized judicial settings, the presence of safeguards facilitates and

promotes an unimpeded speaking environment while protecting an individual

from false or malicious statements[.]” DelMonico v. Traynor, 116 So. 3d

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1205, 1217 (Fla. 2013), abrogated on other grounds by Askew v. Fla. Dep’t

of Child. & Fams., 385 So. 3d 1034, 1036 n.2 (Fla. 2024); see also Arko

Plumbing Corp. v. Rudd, 230 So. 3d 520, 524 (Fla. 3d DCA 2017) (holding

neither absolute nor qualified privilege applied to attorney accessing

opposing party’s company account and only qualified privilege applied to

examination under oath outside formal discovery process). Additionally, the

privilege can apply “in all causes of action, statutory as well as common law.”

Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380,

380–81 (Fla. 2007).

For an act to occur “in the course of a judicial proceeding,” it must be

“in front of a judicial officer or in pleadings or documents filed with the court.”

DelMonico, 116 So. 3d at 1217. In a judicial setting, the court can mitigate

potential harm by “expunging [or striking] irrelevant defamatory matter from

the pleadings, and by punishing for contempt of court the guilty party.” Id.

Because these remedies do not exist for conduct outside of a judicial

proceeding, only a qualified privilege applies when “an attorney steps outside

of both the courtroom and the formal discovery process to investigate a

claim.” Id. at 1218.1

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In contrast to the absolute privilege, Florida’s qualified litigation privilege applies to ex-parte, out-of-court statements, so long as they bear some relation to the underlying lawsuit. DelMonico, 116 So. 3d at 1208. To

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Agnetti argues DelMonico applies only to defamation cases; however,

DelMonico also involved a tortious interference claim. 116 So. 3d at 1209.

Courts continue to apply the DelMonico standard to non-defamation causes

of action. See KAC 2021-1, LLC v. Am. Homes 4 Rent Props. One, LLC, 398

So. 3d 1033, 1037 (Fla. 2d DCA 2024); Arko Plumbing Corp., 230 So. 3d at

524. Alternatively, Agnetti argues that because Askew abrogated DelMonico

on jurisdictional grounds, DelMonico’s standard does not apply. But courts

continue to apply that standard while recognizing Askew abrogated

DelMonico on other grounds. See Grippa v. Rubin, 133 F.4th 1186, 1194

(11th Cir. 2025).

Here, the allegations of Okaloosa LLC’s amended complaint do not

demonstrate a basis for the application of Florida’s absolute litigation

privilege. This is because the allegation that Agnetti (as Tabib’s lawyer in the

Miami Litigation) made phone calls to Fixel (as Okaloosa LLC’s lawyer in the

eminent domain negotiation prior to suit) instructing Fixel to treat Tabib rather

overcome this qualified privilege, the plaintiff must establish express malice. Id. But, “where the statements do not bear some relation to or connection with the subject of inquiry in the underlying lawsuit,” the defendant is not entitled to either privilege. Id. Because the qualified litigation privilege was not raised below or ruled upon by the trial court, we do not reach that issue. Rosich-Medina v. Chilaud, 426 So. 3d 578, 583 (Fla. 3d DCA 2025) (“As an appellate court, we are constrained from making these determinations in the first instance.”).

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than Levy as the owner of Okaloosa LLC does not demonstrate that the

alleged acts occurred during the course of a judicial proceeding. The

amended complaint alleges that the phone calls occurred in January 2021,

and FDOT did not file the Eminent Domain Litigation until December 15,

2021.

Furthermore, while the amended complaint does reflect that the Miami

Litigation overlapped with Agnetti’s phone calls with Fixel—both occurred in

January 2021—these allegations are still insufficient to establish that the

absolute litigation privilege applies. This follows from the alleged acts

themselves—phone calls, which by their nature would not have occurred “in

front of a judicial officer or in pleadings or documents filed with the court.”

DelMonico, 116 So. 3d at 1217. As a result, a trial court would have no

opportunity to mitigate potential harm resulting from such alleged

communications because it could not strike the information because it was

not filed with the court and it could not use its contempt power because the

phone calls did not occur before the court. Id. Therefore, the allegations of

Okaloosa LLC’s amended complaint regarding Agnetti’s phone calls with

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Fixel do not reflect that the alleged acts occurred during the course of a

judicial proceeding.2

The order on appeal cites Cherdak v. Cottone, No. 2:22-cv-634-SPCNPM, 2023 WL 2044608, at *4 (M.D. Fla. Feb. 16, 2023), to show the

absolute privilege applies in this case; however, the materials protected by

the absolute privilege in Cherdak were affidavits to be filed with the court.

Therefore, the remedies listed in DelMonico—expunging or striking

defamatory matter from the pleadings and punishing for contempt of court

the guilty party—were available in Cherdak. DelMonico, 116 So. 3d at 1217.

Here, the alleged phone calls were not before a judicial officer or filed with

the court, and therefore, none of these remedies were available. Id. Because

the alleged phone calls did not occur in the course of a judicial proceeding,

it is unnecessary to consider the second part of the test—whether the

conduct had some relation to the proceeding.

Accordingly, because the allegations of Okaloosa LLC’s amended

complaint failed to show that the alleged acts occurred in the course of a

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Agnetti, as well as the trial court in the order on appeal, cites several federal cases applying Florida law to demonstrate the absolute privilege applies to the phone calls; however, almost all were either decided before DelMonico or did not apply DelMonico. As a result, these courts did not apply the controlling standard DelMonico created to determine whether conduct occurred in the course of a judicial proceeding. See DelMonico, 116 So. 3d at 1217–18.

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judicial proceeding, the trial court erred in concluding that the absolute

litigation privilege applied. We therefore reverse the trial court’s order of

dismissal and remand for further proceedings.

Reversed and remanded.

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