Florida House Rules & Ethics Committee Chair, next Florida Speaker of the House, 2026-2027, seeking contract violation of public policy to be St. Johns County Attorney. From his law firm web page:
Tuesday, April 08, 2025
Ask Questions, Demand Answers & Expect Democracy: April 10, 2025 Anastasia Mosquito Control District of St. Johns County Meeting, 5 PM
Sent: Tuesday, April 8, 2025 at 02:21:46 PM EDT
Subject: AMCD Chair Becker, please modify our April 10, 2025 Anastasia Mosquito Control District Commission agenda
To: Anastasia Mosquito Control Commission of St. Johns County Chair Pangiotta "Trish" Becker.
Dear Chair Becker:
A. Would you please be so kind as to direct AMCD Director Dr. Xue and AMCD staff to kindly cease and desist from manipulating our AMCD agendas to avoid and prevent public debate about Anastasia Mosquito Control Commission of St. Johns County mismanagement?
B. Please add to the April 10, 2025 AMCD discussion agenda:
1. Monthly Financial Report. (Should never be on Consent Agenda again).
2. DVEC/Mosquito Museum cost overruns (41%), including statsus of Museum completion and cost overruns, which currently stand at 41% over the original budget. This increase is reflected in the June 2024 total cost resolution.
3 Reforming District contracting procedures.
4. Draft FY 2026 AMCD budget.
5. Independent Auditor Selection Committee, a state requirement avoided and evaded by AMCD.
6. Etiology of the "Friend of the City of St. Augustine" status conferred on Chair Becker on St. Augustine Facebook page on April 4, 2025 at 4 PM.
7. Evaluation of District's Whistleblower Protection Policy, complaint procedure and compliance with nondiscrimination laws.
8. Please vote to remedy District's noncompliance with my 2024-2025 Open Records requests.
9. Please agree to mediation by Florida Assistant Attorney General Pat Gleason, Special Counsel for Open Government, of my Open Records requests. AMCD never responded to my request for mediation.
10. Please vote to refrain from ever again informing the public that on DVEC Museum that AMCD is "within budget," as this statement appears to be materially false and misleading. Cost overruns of +41%. Outrageous., The forced resolution budget number is being used as the basis, which does not accurately reflect the District's true financial status. It is important to disclose to the public that the District went over budget by $1 million without obtaining any Board approval.
11. Please place on our agenda a report on the status of the Florida StateAttorney Opinion regarding Board members returning their illegally received bonuses for the 2022/2023 fiscal year.
12. Please place on our April 10, 2025 agenda a motion for the Board to instruct SGR legal counsel to look into the allegations of pay-to-play involving Dr. Xue. There have been allegations made by former commissioners that Dr. Xue allegedly paid and/or offered to pay commissioners in cash or offered them District positions in exchange for their support of his continued employment or for voting in a specific manner. Additionally, there are allegations that current Board members may have received cash or had personal expenses covered by Dr. Xue to secure their loyalty.
CONCLUSION: AMCD MUST STOP ITS LAWBREAKING
Chair Becker, you broke your word to me, in writing, about a meeting on records noncompliance.
Chair Becker, you never got back to me with a date for meeting on my records requests.
At our March AMCD meeting, a retired Smith, Gambrell & Russell partner, now "Of Counsel," took the place of Ms. Hodges due to an asserted schedule conflict. That lawyer wrongfully obstructed my right to comment on three (3) agenda items until after they were voted. This was illegal, insouciant and uncouth.
Chair Becker, you suffered and permitted that violation of my rights.
The SGR "Of Counsel" was wrong.
His services, such as they are, may no longer be required.
We have a Right to Know. It's our money.
As James Madison wrote W.T. Barry August 4, 1822, "A popular Government, without popular information, or the means of acquiring it, is but a prologue to a Farce or a Tragedy; or perhaps both. Knowlege will for ever govern ignorance: and a people who mean to be their own Governours, must arm themselves with the power which knowledge gives." Our Florida Sunshine and Open Records laws were adopted as Article I, Section 24 of our Florida Constitution in 1992, by vote of 3.8 million Florida voters (83%). Sadly, some local governments opposed it, and some still seek to undermine it. Sadly, some AMCD staff have violated these rights, enforcing a de facto oath of omertà, concealing documents from Commissioners, Board members and citizens. "Secrecy is for losers," as the late Senator Daniel Patrick Moynihan said it best. See Senator Moynihan's book, SECRECY: the American Experience (1999).
Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
(904) 377-4998
On Thursday, March 20, 2025 at 12:05:07 PM EDT, Ed Slavin <easlavin@aol.com> wrote:
Dear Dr. Qualls:
1. Your responses are, at best, facetious.
2. Will AMCD kindly agree to mediation by the Special Counsel for Open Government, Ms. Pat Gleason?
Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
Non-delegation doctrine counsels against hiring a corporate law firm as St. Johns County Attorney.
On April 7, 2025, I wrote Florida State Representative Judson Sapp (R), asking him to help St. Johns County with its proposed hiring of a corporate law firm to be our St. Johns County Attorney.
Dear Rep. Sapp and Ms. Robbins:
1. I am still waiting on St. Johns County to respond to my several related records requests from February 17, 2025 (seven weeks ago -- 49 days!)
2. SJC is engaged in "massive resistance." Cui bono? ("Who benefits?")
3. I have repeatedly asked SJC to agree to mediation by Ms. Pat Gleason, AAG and Special Counsel to the Florida Attorney General for Open Government. No response.
4. Would you be susceptible of contacting St. Johns County to inquire as to the status of my requets?
5. Rep. Sapp, would you kindly consider supporting legislation to assure that the position of County Attorney cannot be delegated to a corporate law firm, with undisclosed private clients benefitting from certain misguided elected officials' "influence?"
6. In our system of checks and balances, including our Florida Constitution Article I, Section 24, adopting with 3.8 million votes in 1992 (83%) our Sunshine and Open Records laws, the position of St. Johns County Attorney must always be held by a living, breathing natural person licensed by the State of Florida. No corporate law firms are desired or required.
7. Our Founding Fathers are watching what we do here.
8. Would you please consider requesting a State Attorney General's opinion on this issue?
.....
There is no public benefit to hiring a corporate firm as the County Attorney for St. Johns County.
Thank you for all that you do, Ms. Robbins and Rep. Sapp!.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
(904) 377-4998
------
More:
1. Under the "non-delegation doctrine," in Justice Cardozo's words, it is "delegation run riot" to delegate a core government function (County Attorney) to a corporate law firm? You tell me.
2. No scholarly research on this question has ever been provided to the St. Johns County Board of County Commissioners by the law firm in quo, which demands we outsource our St. Johns County Attorney position to a private law firm, BRADLEY, GARRISON & KOMANDO, P.A., in which the future Florida House Speaker (and current Florida House Rules and Ethics Committee Chair) is a named partner.
3. The non-delegation doctrine is alive and well, as it was when the United States Supreme Court overturned the National Industrial Recovery Act, which wrongfully delegated rulemaking functions to private iindustry. See, e.g., A.L.A. Schechter Poultry Corp. v. United States, 295 U.S. 495, 551, 553 (1935)(Cardozo, J., concurring)("the Sick Chicken" case); Panama Refining Co. v. Ryan, 293 U.S. 388 (1935)(the "Hot Oil" case); Carter v. Carter Coal Co., 298 U.S. 238 (1936)("Bituminous Coal Conservation Act of 1935" delegation of price-fixing to private parties).
4. No contract has yet been presented. But SJC County Commissioners voted 3-2 in support of this contract violation of public policy. Restatement of Contracts, 2d, sec 178 (Contract Violation of Public Policy).
Monday, April 07, 2025
Conflict of Interest? St. Johns County, Florida Hiring "Influence" of Florida House Speaker-Designate SAM GARRISON
Update, April 8, 2025: STILL WAITING FOR RECORDS FROM Florida House Speaker-designate SAMUEL PAUL GARRISON, who stands to profit from a controversial St. Johns County Attorney contract, a contract violation of public policy rubber-stamped by Commissioners on 3-2 vote on March 25, 2025.
I sent a third e-mail to County, which has not informed me about the date and time of the negotiation meeting, despite repeated requests to Commission Vice Chair Clay Murphy: Commissioner Murphy said that the date for the negotiation meeting has not yet been set, but that he will advise me when it is scheduled, so that I can attend.
We don't need to hire as County Attorney a corporate law firm owned by a Florida elected official.
We don't need to empower land-raping speculators to hire the County Attorney as private counsel.
We don't need any more flummery, dupery and nincompoopery from unjust stewards.
We must drive the money changers from the temple of our democracy.
Enough.
On Friday, March 28, 2025 at 03:27:56 PM EDT, Ed Slavin <easlavin@aol.com> wrote:
Dear Speaker-designate Garrison and Ms. Dixon::
Would you please be so kind as to tell me today the proposed date, time, place and agenda of the St. Johns County Attorney contract negotiation meeting between Vice Chair Clay Murphy and the law firm of Florida House Speaker-designate SAMUEL PAUL GARRISON?
Please send all related documents by PDF today, including draft contract and draft and final public Sunshine notice of negotiation meeting.
Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
(904) 377-4998
Earlier, I sent a followup e-mail to Speaker-designate GARRISON and County:
On Friday, March 28, 2025 at 02:32:49 PM EDT, Ed Slavin <easlavin@aol.com> wrote:
Dear Speaker-designate Garrison and Ms. Dixon:
1. Please send me PDFs of the requested records today,
2. When would our Florida House Speaker-designate, Rep. SAMUEL PAUL GARRISON be available for an interview, either this weekend or on Monday, March 31, 2025, about his BRADLEY, GARRISON & KOMANDO, P.A. law firm's proposed role as our St. St. Johns County Attorney based on "influence?"
3. I look forward to hearing from both of you later today.
Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
(904) 377-4998
Pray for putative "reform" St. Johns County Commissioner Clay Murphy to reconsider his rash decision, joining with two pro-developer hick hack sad sacks, tatterdemalion Commissioners CHRISTIAN WHITEHURST and SARAH ARNOLD, uninformed, uneducated and gullible as usual.
On Thursday, March 27, 2025 at 01:39:10 PM EDT, Ed Slavin <easlavin@aol.com> wrote:
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To Honorable Samuel Paul Garrison, Florida House Speaker-elect & Florida House Ethics Committee Chair
and Ms. Betty Dixon, St. Johns County Attorney's office:
Dear Speaker-elect Garrison and Ms. Dixon:
1. Would you please be so kind as to send me by tomorrow all Florida Bar, Florida Ethics Commission, Florida Attorney General, Florida House of Representatives or other legal opinions or requests for them, and all correspondence, on Speaker-elect Garrison's corporate law firm (BRADLEY, GARRISON & KOMANDO, P.A.) and its proposed hiring as the County Attorney for St. Johns County, one of the fastest-growing counties in the State of Florida, on the basis of Speaker-elect SAMUEL PAUL GARRISON's "influence?"
(Statement of Commission Vice Chair, Clay Murphy, on video, here: Mar 25, 2025 Special Board of County Commissioners - St. Johns County, FL
2. Florida law, F.S. 112.311, states:
Legislative intent and declaration of policy:
(5) It is hereby declared to be the policy of the state that no officer or employee of a state agency or of a county, city, or other political subdivision of the state, and no member of the Legislature or legislative employee, shall have any interest, financial or otherwise, direct or indirect; engage in any business transaction or professional activity; or incur any obligation of any nature which is in substantial conflict with the proper discharge of his or her duties in the public interest. To implement this policy and strengthen the faith and confidence of the people of the state in their government, there is enacted a code of ethics setting forth standards of conduct required of state, county, and city officers and employees, and of officers and employees of other political subdivisions of the state, in the performance of their official duties. It is the intent of the Legislature that this code shall serve not only as a guide for the official conduct of public servants in this state, but also as a basis for discipline of those who violate the provisions of this part.
(6) It is declared to be the policy of the state that public officers and employees, state and local, are agents of the people and hold their positions for the benefit of the public. They are bound to uphold the Constitution of the United States and the State Constitution and to perform efficiently and faithfully their duties under the laws of the federal, state, and local governments. Such officers and employees are bound to observe, in their official acts, the highest standards of ethics consistent with this code and the advisory opinions rendered with respect hereto regardless of personal considerations, recognizing that promoting the public interest and maintaining the respect of the people in their government must be of foremost concern.
F.S. 112.311
C. As I wrote our St. Johns County Board of County Commissioners on March 17, 2025 (items renumbered):
1. Conflicts of interest must be scrupulously guarded against. See, e.g., United States v. Mississippi Valley Generating Co., 364 U.S. 520, 548 (1961)("the 'Dixon-Yates' case," involving TVA rivals' conflicts of interest in a proposed Memphis coal-fired powerplant), citing Matthew 6:24 -- "no [person] can serve two masters," holding that laws and rules preventing conflicts of interest are aimed "not only at dishonor but at conduct that tempts dishonor."
2. All conflict of interest laws are based upon Matthew 6:24 ("A man cannot serve two masters"), which the unanimous Supreme Court decision by Chief Justice Earl Warren deemed to be both a "moral principle" and a "maxim which is especially pertinent if one of the masters happens to be economic self-interest."
3. {Speaker-elect SAM GARRISON's law partner] Mr. [RICHARD CHRISTIAN] KOMANDO unilaterally refuses to disclose the identity of his law firm clients, not client confidences. His overbearing assertion of privilege is unadorned by any citation to any court or ethics opinions on lawyers who are government employees. This flunks the "laugh test." It also flunks the "smell test." Mr. KOMANDO said he would not apply for the permanent County attorney position. Now, aving applied for the permanent position, Mr. KOMANDO is in no position to withhold information that is materially relevant to his suitability to be our St. Johns County Attorney. Mr. KOMANDO is acting as if he were the judge in his own case. This is so wrong.
4. James Madison wrote in The Federalist No. 10: "No [person] is allowed to be a judge in [his/her] own cause, because his interest would certainly bias his judgment, and, not improbably, corrupt his integrity. With equal, nay with greater reason, a body of men are unfit to be both judges and parties at the same time . . . ."
5. The United States Supreme Court held in In re Murchison, 349 U.S. 133, 136 (1955) (Black, J.), "[O]ur system of law has always endeavored to prevent even the probability of unfairness. To this end no man can be a judge in his own case and no man is permitted to try cases where he has an interest in the outcome." See also TWA v. Civil Aeronautics Board, 102U.S. App. D.C. 391, 392, 254 F.2d 90, 91 (1958). Spencer v. Lapsley, 20 How. 264, 266 (1858); Publius Syrus, Moral Sayings 51 (D. Lyman transl. 1856) ("No one should be judge in his own cause."); Blaise Pascal, Thoughts, Letters and Opuscules 182 (Wight transl. 1859) ("It is not permitted to the most equitable of men to be a judge in his own cause."). As William Blackstone wrote, "[I]t is unreasonable that any man should determine his own quarrel," 1 W. Blackstone, Commentaries on the Laws of England 91 citing Dr. Bonham's Case, 8 Rep. 114a (C.P. 1610); see also City of London v. Wood, 12 Mod. 669, 687 (1701)(Lord Holt)(invalidating fine for refusal to serve as sheriff recovered by the city in its own court of Mayor and Aldermen). See also Aetna Life Ins. Co. v. Lavoie, 475 U.S. 813 (1986)(overruling case where Chief Justice of Alabama Supreme Court wrongfully sat in judgment of case that would set precedent for his own pending case); Ward v. Village of Monroeville, 409 U.S. 57 (1972); Gibson v. Berryhill, 411 U.S. 564 (1973); Withrow v. Larkin, 421 U.S. 35 (1975); Cinderella Career and Finishing Schools, Inc. v. FTC, 425 F.2d 583 (D.C. Cir. 1970); American Cyanamid Co. v. FTC, 363 F.2d 757 (6th Cir. 1966); SCA Services, Inc. v. Morgan, 557 F.2d 110 (7th Cir.1977).
6. Being a secretive developer "team player" is not a bona fide occupational qualification in hiring a County Attorney.
7. No "team players" are desired or required here. "Team player" is freighted with the speech-chilling implication that one is willing to "go along to get along," say what management wants to hear, and do what one is told by managers, no matter what the ethics or legality of the situation. In the political corruption case of United States v. Salvatti, 451 F.Supp. 195, 197-98 (E.D. Pa. 1978), one witness testified that "when she complained to the Mayor about Mr. Carroll's pressure, and advised him that the proposed payment to the Sylks would be totally improper and probably illegal, the Mayor chided her for not being a team player." See also Fitzgerald v. Seamans, 384 F.Supp. 688,697n7 (D.D.C. 1974), affirmed, 553 F.2d 220, 224 (D.C. Cir. 1977), reversed, Harlow v. Fitzgerald, 457 U.S. 800 (1982); Nixon v. Fitzgerald, 457 U.S. 731 (1982) (remarks of President Nixon et al. on need to fire heroic Department of Defense whistleblower A. Ernest Fitzgerald after he testified truthfully before Congress on C-5A transport cost overruns, with Nixon saying Mr. Fitzgerald was "not a team player"); Broderick v. Ruder, 685 F.Supp. 1269 (D.D.C. 1988)(sexual harassment at Securities and Exchange Commission); Tomsic v. State Farm Mutual Automobile Insurance Co, 85 F.3d 1472, 1474 (10th Cir. 1996); Geddes v. Benefits Review Board, 735 F.2d 1412, 1416, 1420 (D.C. Cir. 1984) (Washington Metropolitan Transportation Authority considered workers' compensation claimant not a "team player"); Davis v. California, 1996 WL 271001 (E.D.Cal.1996); Schloesser v. Kansas Dept. of Health & Environment, 766 F.Supp. 984 (D. Kansas 1991); Stradford v. Rockwell International, 48 Fair Empl.Prac.Cas. (BNA) 697, 49 Empl. Prac. Dec. P 38,828,1988 WL 159939 (S.D.Ohio); Seymour M. Hersh, "Annals of National Security: The Intelligence Gap -- How the digital age left our spies out in the cold," The New Yorker, December 6, 1999 at 58, 62.
8. Commissioners, please feel free to call me to discuss.
Thank you.
With kindest regards, I am, 
Sincerely yours,
Ed Slavin
Box 3084
St. Augustine, Florida 32085-3084
www.edslavin.com
(904) 377-4998
