Preediction: Dade County Circuit Court will likely invalidate the illegal land transfer for violating Florrida's Sunshine law. Three cheers for Professor. Marfin Dunn, Ph.D. and his learned counsel, University of Miami Professor Andres Rivero for bringing this lawsuit. From The New York Times:
Judge Temporarily Blocks Transfer of Miami Property for Trump Library
A judge said that a state college had failed to provide reasonable public notice before taking steps to convey the land it owned.
Reporting from Miami
A Florida judge temporarily blocked on Tuesday the transfer of a prime property in downtown Miami to President Trump for his presidential library, saying that a state college had failed to provide reasonable public notice before taking steps to convey the land it owned.
Judge Mavel Ruiz of Florida’s 11th Judicial Circuit found that the board of trustees of Miami Dade College most likely violated the state’s Sunshine Law, which requires a certain degree of transparency in government. She said that lawyers working on the paperwork to deed the property to the nonprofit that is raising money for Mr. Trump’s presidential library should temporarily pause that work.
Judge Ruiz’s ruling does not permanently block the state from conveying the property to Mr. Trump, as Gov. Ron DeSantis and other Republican state officials voted to do on Sept. 30. The college trustees could meet again, this time providing more specific public notice, for the property transfer to be properly completed.
“It is understood that the board can provide the reasonable disclosure and convey this property as they see fit,” Judge Ruiz said in her ruling, which followed hearings on Monday and Tuesday. “That’s why this is not a case, at least for this court, rooted in politics.”
At issue was a special meeting the board held on Sept. 23. There, trustees voted without discussion to transfer the 2.63-acre property with waterfront views to the state. The meeting lasted less than five minutes.
Mr. DeSantis and the Florida cabinet — the state attorney general, agriculture commissioner and chief financial officer — then met on Sept. 30 to hand over the property to Mr. Trump’s foundation.
The college received a letter from the state Office of Cabinet Affairs on Sept. 16 requesting the conveyance without any explanation. There had been public speculation over the summer about Mr. Trump and his advisers eyeing the property.
The only public notice issued ahead of the Miami Dade College trustees’ meeting said that the board would “discuss potential real estate transactions,” without any specifics.
On Tuesday, the judge granted a temporary injunction on the property transfer sought by Marvin Dunn, a Miami historian, who said the public should have been given specific notice about, and an opportunity to comment on, the property transfer before it was approved.
Lawyers for the board countered that they had given ample notice about the meeting and had met the minimum specificity required by state law.
“The Sunshine Law does not require an agenda,” Carmen Manrara Cartaya, a lawyer for the board, said in Monday’s hearing.
Jesus M. Suarez, another lawyer for the board, said the trustees planned to appeal the judge’s decision, saying in an email after the ruling that the meeting was “lawfully noticed in all respects.”
The Sunshine Law does not require much specificity in such a notice, Judge Ruiz acknowledged. But she cited prior case law that found that “fair and reasonable” notice should apprise the public of matters that might affect their rights and afford them “the opportunity to appear and present their views.”
“The court does not believe that the notice was reasonable,” she said.
Miami Dade College bought the property for about $25 million in 2004. Its value today is listed by the county at more than $67 million, but that is just a fraction of its likely market value, which at least one real estate consultant has pegged at $360 million at the minimum.
Patricia Mazzei is the lead reporter for The Times in Miami, covering Florida and Puerto Rico.
Here is the text of Dr. Marvin Dunn's lawsuit:
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO. ___________________________
Dr. MARVIN DUNN
v.
MIAMI DADE COLLEGE; DISTRICT
BOARD OF TRUSTEES OF MIAMI DADE
COLLEGE; AND MICHAEL BILECA,
ROBERTO ALONSO, MARIA BOSQUE BLANCO,
MARCELL FELIPE, ISMARE MONREAL, AND
JUAN SEGOVIA, IN THEIR CAPACITY AS
MEMBERS OF THE DISTRICT BOARD OF TRUSTEES
OF MIAMI DADE COLLEGE,
defendants.
__________________________________________________/
VERIFIED COMPLAINT FOR INJUNCTION BASED
ON VIOLATION OF FLORIDA’S GOVERNMENT IN THE SUNSHINE ACT
Plaintiff, Dr. Marvin Dunn, sues defendants MIAMI DADE COLLEGE, DISTRICT
BOARD OF TRUSTEES OF MIAMI DADE COLLEGE, AND MICHAEL BILECA,
ROBERTO ALONSO, MARIA BOSQUE BLANCO, MARCELL FELIPE, ISMARE
MONREAL, AND JUAN SEGOVIA, in their capacity as members of the District Board of
Trustees of Miami Dade College, and, on verification, alleges as follows:
A. Nature of Action
1. This is an action for an injunction under the Florida Government in the Sunshine Act,
Chap. 286, Fla. Stat., and a parallel provision of the Constitution of the State of Florida.
2. On September 23, 2025, Miami Dade College’s District Board of Trustees voted to
give away, for nothing, one of the institution’s most valuable assets—a 2.6-acre piece of prime
real estate (the “Land”)—to the State of Florida, so the State could give it to the Donald J. TrumpPresidential Library Foundation, Inc. That Foundation would then have five years to start
construction of “components of a Presidential library, museum, and/or center.” Neither the
College nor the State has said anything about what else could be developed on this parcel. Nor is it
stated what is meant by “components of a Presidential library, museum and/or center,
” or, for that
matter, by “a Presidential library, museum and/or center.” The State has since resolved to transfer
the land to the Trump Foundation.
3. This action does not have to do with whether the District Board of Trustees made a wise
decision. It is not brought to lodge a political protest. Rather, it deals with the fact that, in making its
decision, the District Board of Trustees unquestionably violated Florida’s sacrosanct Government in
the Sunshine Act and the parallel (and underpinning) provisions of Article I, section 24, of the
Constitution of the State of Florida (the “Constitution”).
1
4. There can be no reasonable dispute that the College, the District Board of Trustees, and
its members are covered by the referenced provision of the Constitution and by the Sunshine Act.
Rather, the question is: did the District Board violate those provisions of law in giving away the
Land? If so, the decision is void ab initio.
5. The Sunshine Act requires “reasonable notice” to the public of a future meeting. The
notice in this case provided the opposite of reasonable notice. The only thing that the College said to
describe the purpose or agenda of the meeting was this:
At this Special Board Meeting, the District Board of Trustees will discuss potential
real estate transactions.
6. This “notice” is unquestionably inadequate, and therefore unreasonable. This was not,
in any way, a typical or run-of-the-mill “real estate transaction.” The proposed giveaway cannot
1 Unless the context dictates otherwise, all references to the Sunshine Act should be understood
also to be references to Art. I, section 24, Fla. Const.
2even charitably be characterized as a “transaction.” No one not already in on the deal would have
had any idea from this “notice” of what the District Board of Trustees was actually planning to do.
In fact, the Vice Chairman of the District Board has claimed that the Board was unaware of the
purpose of the decision but went ahead and voted for it because the Governor instructed them to do
so.
7. Depriving the public of reasonable notice of this proposed decision was a plain
violation of the Sunshine Act and of the Florida Constitution. It is unavoidable that the transfer of
this Land must be enjoined and the decision to do so found to be void ab initio.
8. Plaintiff, as a citizen of this State, brings this action under the Sunshine Act to enjoin
the transfer of the Land to the State of Florida. This action is filed to hold the defendants to the law
and to provide adequate public input into a momentous decision.
B. Parties
9. 10. institution. It is part of the “Florida College System. §§ 1000.21(5)(o), 1001.60(2), Fla. Stat.
11. Plaintiff is a citizen of the State of Florida.
Miami Dade College (the “College”) is a public post-secondary educational
As provided for under Florida law, the College is governed by a board of trustees,
called the District Board of Trustees (“District Board”) whose members are appointed by the
Governor, subject to confirmation by the Florida Senate. §§ 1001.60-1001.64, Fla. Stat.
12. At all times material to this action, the members of the District Board were (and, on
information and belief, are): Michael Bileca (Chair), Roberto Alonso (Vice Chair), Maria Bosque
Blanco, Marcell Felipe, Ismare Monreal, and Juan Segovia. They are named in this action in their
capacity as District Board Trustees.
3C. The Constitution and the Sunshine Act
13. Article I, section 24(b) of the Constitution provides:
All meetings of any collegial public body of the executive branch of state
government or of any collegial public body of a county, municipality, school
district, or special district, at which official acts are to be taken or at which public
business of such body is to be transacted or discussed, shall be open and noticed to
the public and meetings of the legislature shall be open and noticed as provided in
Article III, Section 4(e), except with respect to meetings exempted pursuant to this
section or specifically closed by this Constitution.
14. The Sunshine Act covers “any board or commission of any state agency or authority
or of any agency or authority of any county, municipal corporation, or political subdivision,
except as otherwise provided in the Constitution”. § 286.011, Fla. Stat.
15. 16. The College, the District Board, and its members, are covered by the Sunshine Act.
The Sunshine Act provides that “all meetings” of an organization or individual
covered by the Act “at which official acts are to be taken are declared to be public meetings open
to the public at all times, and no resolution, rule, or formal action shall be considered binding
except as taken or made at such meeting.” § 286.011(1), Fla. Stat.
17. The Florida Supreme Court has instructed the courts of this state that “the law must
be broadly construed to effect its remedial and protective purpose,” which is “to protect the
public from closed door politics” and “to frustrate all evasive devices.” Sarasota Citizens for
Responsible Gov’t v. City of Sarasota, 48 So. 3d 755, 762 (Fla. 2010) (citations omitted). Thus,
“[m]ere showing that the government in the sunshine law has been violated constitutes an
irreparable public injury,” and “where officials have violated section 286.011, the official action
is void ab initio.” Id. (citation omitted).
18. The Sunshine Act also provides: “The board or commission must provide reasonable
notice of all such meetings.” Id. “Reasonable notice” is not defined in the Sunshine Act. The
4reasonableness of notice is thus a fact-specific inquiry. “[T]he type of notice given depends on
the purpose for the notice, the character of the event about which the notice is given, and the
nature of the rights to be affected.” Att’y General Opinion 73-170 (discussing “due notice” as
then required under Sunshine Act).
19. While the Attorney General’s Office has recommended “publication of an agenda, if
available,” published agendas listing specific notice of each item to be discussed are not required
by the Sunshine Act. AG Manual at 39-40. Nevertheless, agencies must provide notice thereof if
required to do so under “other statutes, charter provisions, ordinances, or rules that may also
apply and be more restrictive as to the type of notice and agenda required for a public board or
commission to conduct its business.” AG, Inf. Op. to Mattimore, February 6, 1996, available at
https://www.myfloridalegal.com/ag-opinions/agenda-of-public-boards-requirements.
20. The College’s Manual of Procedures states: “Any agreements that require approval
by The District Board of Trustees must be accompanied by a Board agenda item in appropriate
format prepared by the Originator.” Man. Proc. 6300.D.1, available at https://www.mdc.edu/
procedures/Chapter6/6300.pdf (Attachment 1).
21. Members of the public shall be given a reasonable opportunity to be heard on a
proposition before a board or commission.2 The opportunity to be heard need not
occur at the same meeting at which the board or commission takes official action
on the proposition if the opportunity occurs at a meeting that is during the
decisionmaking process and is within reasonable proximity in time before the
meeting at which the board or commission takes the official action.
Finally, Section 286.0114(2), Fla. Stat., provides that:
2 “For purposes of [s. 286.0114], ‘board or commission’ means a board or commission of any
state agency or authority or of any agency or authority of a county, municipal corporation, or
political subdivision.”
5§ 286.0114(2), Fla. Stat.3
D. Plaintiff’s Standing
22. Section 286.011(2) provides that “[t]he circuit courts of this state shall have
jurisdiction to issue injunctions to enforce the purposes of this section upon application by any
citizen of this state.” “The Sunshine Law ‘on its face[] gives the appellant standing without
regard to whether he suffered a special injury.’” Godheim v. City of Tampa, 426 So. 2d 1084,
1088 (Fla. 2d DCA 1983); see Silver Exp. Co. v. District Bd. of Lower Tribunal Trustees of
Miami-Dade Community College, 691 So. 2d 1099 (Fla. 3d DCA 1997) (“Sunshine Law . . . was
enacted so as to permit any citizen to vindicate the public’s interest in open government.”).
E. Violation of Sunshine Act
23. At a Special Meeting held on September 23, 2025, the District Board, at a meeting
that, on information and belief, all members of the District attended, decided to give—that is,
transfer, for nothing—a 2.63-acre parcel of land the College owned, at 500 Biscayne Boulevard,
Miami, Florida, to the State of Florida’s Internal Improvement Trust Fund (the “Fund”).4 The
members of the Board of the Fund are the members of the Florida Cabinet (Governor Ron
DeSantis, Attorney General James Uthmeier, Chief Financial Officer Blaise Ingoglia, and
Commissioner of Agriculture Wilton Simpson).
3 Section 286.0114(8) provides that an action taken by an agency in violation of section 286.0114
is not void.
4 Although Plaintiff has located on the Web both the notice of the meeting for this decision and
the agenda item, he has been unable to locate a copy of the minutes of the meeting or the text of
any resolution. The Court can take judicial notice of the decision of the District Board. See sec.
90.202, Fla. Stat.--(11) Facts that are not subject to dispute because they are generally known
within the territorial jurisdiction of the court; (12) Facts that are not subject to dispute because
they are capable of accurate and ready determination by resort to sources whose accuracy cannot
be questioned.
624. On information and belief, the Land is extremely valuable. One published estimate
of its value is $360 million. Patricia Mazzei, Florida Hands Over Prime Miami Property for
Trump Library, The New York Times, Sept. 30, 2025 (Attachment 2). The Miami-Dade County
Property Appraiser (“PA”) currently reports its “appraised value” and “market value” as
approximately $67 million. It is widely known and understood that the PA’s published estimates
of “appraised” and “market” value are substantially lower than actual market value.5
25. According to Vice Chair Alonso, the District Board took this action because the
Office of the President of the United States requested the Board, without explanation, to convey
the Land to the State, so that, according to Alonso, he and his fellow District Board members did
not know what the request was for. But, he said, “[t]here’s not many options—we’re appointed
by the Governor.” Mazzei, id. Alonso, interviewed on local television, made no mention of the
request from the Federal Government, and said that they “had received a request by the State to
convey over a piece of property on our Wolfson Campus.” WPLG, This Week in South Florida:
Roberto Alonso (Sept. 28, 2025), at 1:25-1:28, available at https://www.local10.com/this-week-
in-south-florida/2025/09/28/this-week-in-south-florida-roberto-alonso/.
26. Irrespective of the specific circumstances of this giveaway, the speedy and uncritical
transfer of the Land to the State for nothing, without any serious deliberation, without any
economic analysis, and, on information and belief, solely because the Governor or the President,
or both, wanted the District Board to do so, was a violation of the duty of care owed to the
College by the Board members. Specifically, Florida law permits a College Board of Trustees to
5 The Land is composed of twelve adjacent parcels of land, listed on the Property Appraiser’s
website as 500 Biscayne Boulevard. The appraised and market values of these parcels were
obtained by clicking on each of the twelve parcels at https://apps.miamidadepa.gov/
PropertySearch/#/ with the above address.
7“purchase, acquire, receive, hold, own, manage, lease, sell, dispose of, and convey title to real
property,” but only “in the best interests of the [College].” § 1001.64(37) Fla. Stat.
27. On information and belief, contrary to the Vice Chair’s claim that the District Board
was kept in the dark about what the transfer was for but agreed to the giveaway anyway—which,
if true, is an admission of the abject failure of the Board members to fulfill their duties in a
reasonable manner—the District Board knew full well when it agreed to transfer the land for
nothing what the real purpose of the exercise was.
28. The real purpose of the giveaway was to enable the State of Florida, through the
Fund, to give the land to the Donald J. Trump Presidential Library Foundation, Inc. (“Trump
Foundation”), in the words of the Fund’s agenda, “free from any waiver, encumbrance, or
restriction except for the requirement that the subject parcel contains components of a
Presidential library, museum, and/or center within five years of conveyance or that construction
has commenced for a Presidential library, museum, and/or center.” Agenda, Board of Trustees of
Internal Improvement Trust Fund, Sept. 30, 2025, available at
https://floridadep.gov/sites/default/files/09302025_ BOT%20 Agenda_2.pdf (Attachment 3). The
State has announced that the Fund’s Trustees have voted to give the land to the Trump
Foundation. Governor Ron Desantis and Cabinet Deed Land for the Donald J. Trump
Presidential Library (Sept. 30, 2025), available at https://www.flgov.
com/eog/news/press/2025/governor-ron-desantis-and-cabinet-deed-land-donald-j-trump-
presidential-library (Attachment 4).
29. Notice of the Special Meeting was given as follows:
a. Notice of the September 23, 2025, Special Meeting was provided on
September 16, 2025. Public Notice: Notice of Special Board Meeting of District Board of
8Trustees of Miami Dade College, available at https://news.mdc.edu/pressrelease/public-notice-
notice-of-special-board-meeting-district-board-of-trustees-miami-dade-college-09302025/
(Attachment 5). It is not known at the time of filing of this action what distribution was made of
this Notice other than posting it on the College’s website.
b. The only description of the purpose of the meeting in the “notice” was
as follows: “At this Special Board Meeting, the District Board of Trustees will discuss
potential real estate transactions.”
30. This “notice” was unquestionably inadequate, and therefore unreasonable. This was
not, in any way, a typical or run-of-the-mill “real estate transaction.” No one not already in on the
deal would have had any idea from this Notice of what the District Board of Trustees was actually
planning to do. In fact, the Vice Chair of the District Board has claimed that the Board was unaware
of the purpose of the decision but went ahead and voted for it because the Governor instructed them
to do so.
31. An agenda for the District Board’s Special Meeting was prepared. It is not known at
the time of the filing of this pleading whether this agenda was made public, or when. The agenda
stated that the only “action item” was “AUTHORIZATION TO CONVEY PROPERTY TO THE
BOARD OF TRUSTEES OF THE INTERNAL IMPROVEMENT TRUST FUND OF THE
STATE OF FLORIDA.” See https://www.mdc.edu/about/pdf/2025-trustee-agenda/20250923-
agenda.pdf (Attachment 6) (capital letters in original). Like the notice, the agenda was materially
incomplete and cannot be construed to have provided reasonable notice of the District Board’s
listed agenda item.
F. Public Concern
32. The decision of the District Board has aroused substantial negative comments from
9certain members of the community.
a. The President Emeritus of the College, Eduardo J. Padron, said that
“the land that’s been transferred to the state was meant for an expansion of the college’s Wolfson
campus to accommodate its growing student population,” that “[i]t’s very difficult to understand
this because the public has not had a chance to even have a say on this,” and that “[i]t[‘s] just
frankly unimaginable that this decision was made without any real discussion of the
consequences of what that will do to the college.” Joshua Ceballos and Daniel Rivero, Former
Miami Dade College president calls Trump library land giveaway ‘unimaginable,
’ WLRN (Sept.
2025), available at https://www.wlrn.org/ government-politics/2025-09-25/trump-presidential-
library-miami-dade-college (Attachment 7).
b. Plaintiff and former Florida International University Professor Dr. Marvin
Dunn stated that “[t]he thing about this that really hurts me and outrages me is that they’re taking
land from our kids and giving it to someone for commercial, economic development.” Anthony
Cruz, South Florida community leader calls for investigation of land transfer for future Trump
library, WLRN (Oct. 1, 2025), available at https://www.wlrn.org/government-politics/2025-10-
01/south-florida-community-leader-calls-for-investigation-of-land-transfer-for-future-trump-
library (Attachment 8).
c. Miguel (“Mike”) A. Fernandez, a prominent businessman, called the plan “a
direct theft of educational opportunity for political gain,” and further stated that “[t]his land was
never the governor’s to give away. It belongs to the students. It belongs to the future.” Miguel A.
Fernandez, Stop the political hijacking of Miami-Dade’s future for a Presidential Library, Miami
Herald Op-Ed (Sept. 27, 2025), available at https://www.miamiherald.com/opinion/op-
ed/article312284805.html (Attachment 9).
10G. Conclusion
33. The law requires an injunction against the defendants'giveaway made in the
dark.
WHEREFORE, plaintiff respectfully requests :
1. An injunction against the conveyance of the Land to the State on account of the
violation of the Sunshine Act described here.
2. Attorneys' fees as provided under the Sunshine Act.
3. Such other relief as the Court may deem just and appropriate.
Dated: October 6,2025 Respectfully submitted,
RIVERO MESTRE LLP
2525 Ponce de Leon Blvd., Suite 1000
Coral Gables, Florida 33134
Telephone: (305) 445-2500
Facsimile: (305) 445-2505
E-mail : ariv er o @riveromestre. com
By:
ANDRES RIVERO
Florida Bar No. 613819
and
Richard E. Brodsky
FBN 322520
Attorney atLaw
The Brodsky Law Firm
1805 Ponce de Leon Blvd.
Unit 610
Coral Gables, Florida 33134
Cell: 305-962-7497
rbrodsky@thebrodskylawfirm. com
lsl Richard E. Brodslqt
RICHARD E. BRODSKY
Counselfor Dr Marvin Dunn
11CER CA OF SE CE
I CERTIFY that on october 6,2025,1 electronically filed this document with the clerk
of the Court using the Florida Courts E-Filing portal. I also certifli that this document is being
served on all parties and counser via e-mail generated by the E_portal system.
/s/
ANDRES RIVERO
VERIFICATION
Under penalties of perjury, I declare that I have read the foregoing complaint and that the
facts stated in it are true' where indicated, the facts stated are true to the best of my knowledge
and belief
October 6,2
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