DANIEL MARK ZAVADIL, APPELLANT,
v.
THE FLORIDA BAR, APPELLEE
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Daniel Zavadil appealed the dismissal of his defamation complaint against The Florida Bar, alleging the Bar defamed him by stating he was "disbarred" when his license was actually "revoked." The court affirmed the dismissal, holding that revocation is tantamount to disbarment and that the Bar has absolute immunity for its regulatory actions.
The trial court correctly dismissed the complaint. A revocation of a license is tantamount to a disbarment under Florida Bar rules, and the Bar has absolute immunity for actions taken within the scope of its authority as an arm of the Florida Supreme Court in regulating attorneys.
[1] A bar association is absolutely immune for actions taken within the scope of its authority as an arm of the state's supreme court in regulating attorneys.
[2] Maintaining an accurate public listing of attorneys, including their standing and ability to practice, is an integral part of a bar association's duties.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A revocation of a license can be tantamount to a disbarment. See R. Regulating Fla. Bar 3-5.1(g) ('A disciplinary revocation is tantamount to' a disbarment.').”
Establishes that the terms "revocation" and "disbarment" are legally equivalent, defeating Zavadil's defamation claim based on word choice.
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Join FLexlaw to unlock all legal intelligenceZavadil's law license was revoked by the Florida Supreme Court for making material omissions in his application for admission to the Bar. The Florida …
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On Motion fob Rehearing
We deny the motion for rehearing en banc but grant the motion for a written opinion, withdraw our prior affirmance without opinion, and substitute the following opinion in its place.
■ Affirmed,. The trial court correctly dismissed appellant’s complaint against The Florida Bar for defamation. In his complaint, appellant alleged that the Bar defamed him when it posted in his attorney profile and stated in a letter that he had been “disbarred” when the supreme court had “revoked” his license for making material omissions in his application for admission to the Bar. See Fla. Bd. of Bar Exam’rs ex rel. Zavadil, 123 So.3d 550 (Fla.2013). A revocation of a license can be tantamount to a disbarment. See R. Regulating Fla. Bar 3-5.1(g) (“A disciplinary revocation is tantamount to’ a disbarment.”).1 Moreover, the Bar has absolute immunity' for actions taken within the scope of its authority as an arm of the Florida Supremé Court in the matters of *597the regulation of attorneys. See Mueller v. The Fla. Bar, 390 So.2d 449, 451 (Fla. 4th DCA 1980). The term, “scope of office” has been interpreted broadly, Id. at 451-52. Maintaining an accurate public listing of attorneys, including whether or not they are in good standing and able to practice, is an integral part of the Bar’s duties, as is responding to inquiries regarding an attorney’s status. See, e.g., R. Regulating Fla. Bar 3-5.4;
WARNER, CONNER and FORST, JJ., concur. '
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Citator
Cited By
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Yeyille v. Greenberg Traurig, P.A. (S.D. Fla. 2025)…ectively addresses many of the GT Defendants' other argued grounds for dismissal, also addressed in the State Court proceeding, including that (1) the GT Defendants, as agents of the Florida Bar, are immune from suit, see Zavadil v. The Florida Bar, 197 So. 3d 596-97 (Fla. 4th DCA 2016) (holding that "the Bar has absolute immunity for actions taken within the scope of its authority as an arm of the Florida Supreme Court in the 5 ---PAGE 5--- CONCLUSION Based on the foregoing, it is ORDERED AND ADJUDGED as f…
Authorities Cited
- Mueller v. THE Florida BAR, 390 So. 2d 449 (Fla. 4th DCA 1980)
- Fla. Bd. OF BAR Exam'rs re Daniel Mark Zavadil, 123 So. 3d 550 (Fla. 2013)