Steve Ferguson v. the Republic of Trinidad and Tobago

CourtDistrict Court of Appeal of Florida
DecidedSeptember 10, 2025
Docket3D2023-0880
StatusPublished

This text of Steve Ferguson v. the Republic of Trinidad and Tobago (Steve Ferguson v. the Republic of Trinidad and Tobago) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steve Ferguson v. the Republic of Trinidad and Tobago, (Fla. Ct. App. 2025).

Opinion

Third District Court of Appeal State of Florida

Opinion filed September 10, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-880 Lower Tribunal No. 04-11813 ________________

Steve Ferguson, Appellant,

vs.

The Republic of Trinidad and Tobago, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Reemberto Diaz, Judge.

León Cosgrove Jiménez LLP, and Scott B. Cosgrove and William A. O'Leary; The Law Office of Stephen James Binhak, P.L.L.C., and Stephen J. Binhak; Ropes & Gray LLP, and Douglas Hallward-Driemeier and Isaac C.H. Sommers (Washington, DC) and Philip P. Ehrlich (Chicago, IL), for appellant.

White & Case LLP, and Raoul G. Cantero and James N. Robinson and Ryan A. Ulloa and Wyatt R. Smith (New York, NY), for appellees.

Before LOGUE, GORDO and LOBREE, JJ. LOBREE, J.

Following nineteen years of litigation, with six related interlocutory

proceedings and a month-long trial, Steve Ferguson (“Ferguson”) appeals

from a final judgment rendered upon a jury verdict finding that he committed

civil fraud, conspiracy to commit fraud, and violated Florida’s Civil Remedies

for Criminal Practices Act, sections 772.103(3) and (4), Florida Statutes

(portions of “Florida’s Civil RICO Act”). Upon our thorough review of the

voluminous record evidence viewed in the light most favorable to the jury

verdict, we affirm on all grounds. See Alvarez v. All Star Boxing, Inc., 258

So. 3d 508, 512 (Fla. 3d DCA 2018) (“We review the jury’s award . . . to see

if it is supported by substantial competent evidence viewing the facts and all

reasonable inferences in the light most favorable to the verdict.”). We write

simply to address Ferguson’s argument that no domestic injury to the

Republic of Trinidad and Tobago, et al. (the “Republic”) occurred.1

1 While the concurrence asserts that this is a case of first impression as to whether Florida’s Civil RICO Act may be applied extra-territorially, this is not how Ferguson presented the issue to the trial court. Instead, Ferguson contended that the Republic failed to prove it suffered a domestic injury. Because the specific issue was not raised below, we decline to address whether Florida’s Civil RICO Act may be applied extra-territorially. See Sunset Harbour Condo. Ass’n v. Robbins, 914 So. 2d 925, 928 (Fla. 2005) (“In order to be preserved for further review by a higher court, an issue must be presented to the lower court and the specific legal argument or ground to be argued on appeal or review must be part of that presentation if it is to be

2 Florida’s Civil RICO Act is patterned after its federal counterpart, so

Florida courts look to federal cases for guidance. See Palmas Y Bambu, S.A.

v. E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 n.1 (Fla. 3d DCA

2004). Federal civil RICO claims require a “domestic injury.” See

Yegiazaryan v. Smagin, 599 U.S. 533, 543–44 (2023) (“[D]etermining

whether a plaintiff has alleged a domestic injury [for purposes of RICO] is a

context-specific inquiry that turns largely on the particular facts alleged in a

complaint.” (quoting Smagin v. Yegiazaryan, 37 F.4th 562, 570 (9th Cir.

2022))). “Specifically, courts should look to the circumstances surrounding

the alleged injury to assess whether it arose in the United States. . . . [T]hat

means looking to the nature of the alleged injury, the racketeering activity

that directly caused it, and the injurious aims and effects of that activity.” Id.

Here, domestic injury was shown where many parts of the conspiracy

and racketeering activity occurred in Florida. Most importantly, the payment

of the overinflated bids and bribes to co-conspirators Raul Guiterrez and

Brian Kuei Tung, and the destruction of evidence. Ferguson hatched the

conspiracy in Miami, and executed parts of the conspiracy in Miami, where

he met with conspirators to ensure selection of the project consultant,

considered preserved.” (emphasis added) (quoting Tillman v. State, 471 So. 2d 32, 35 (Fla. 1985))).

3 concealed transfers through an agreement that he fabricated, reviewed

documents relating to conspirators’ illicit payments, and transferred over $1

million to Miami accounts held by Gutierrez. Among other things, the

evidence showed that Ferguson’s co-conspirators lived in and orchestrated

the scheme from Florida, where fake invoices and backdated contracts were

created and a hard drive containing incriminating evidence was destroyed.

Florida-based companies pushed through overpriced bids and funneled

kickbacks to Miami-based accounts, and co-conspirator Gutierrez funneled

millions of dollars from accounts in Miami to Ferguson’s shell accounts at a

Bahamian bank and paid another co-conspirator using checks from a

business located in Miami. Thus, we hold that a domestic injury occurred in

Florida where, over multiple years, wrongful acts and plans were devised,

initiated, and carried out through acts and communications initiated in and

directed towards Florida. See Yegiazaryan, 599 U.S. at 545–46.

Affirmed.

GORDO, J., concurs.

4 Ferguson v. Republic of Trinidad and Tobago Case No. 3D23-0880

LOGUE, J., concurring

Florida’s Civil Remedies for Criminal Practices Act (“Florida Civil

RICO”), section 772.104, Florida Statutes, contains no language limiting its

extraterritoriality. Nor does it contain language requiring proof of a “domestic

injury.” As framed in his initial brief, however, Ferguson argues that “Florida

Civil RICO, which is patterned after federal RICO . . . incorporates the same

presumption against extraterritoriality” as its federal counterpart and

therefore requires proof of a “domestic injury.” This is the necessary premise

to his further argument that Trinidad and Tobago failed to prove a domestic

injury.

In making this argument, Ferguson relies on RJR Nabisco v. Eur.

Cmty., 579 U.S. 325 (2016). In RJR Nabisco, Justice Samuel Alito, writing for

the majority, found that the federal counterpart to Florida Civil RICO had no

extraterritorial application and therefore required proof of a domestic injury.

Id. at 346. In doing so, he set forth “a two-step framework for analyzing

extraterritoriality issues.” Id. at 337. “At the first step,” he held, “we ask

whether the presumption against extraterritoriality has been rebutted—that

is, whether the statute gives a clear, affirmative indication that it applies

5 extraterritorially.” Id. “If the statute is not extraterritorial,” he wrote, “then at

the second step we determine whether the case involves a domestic

application of the statute,” i.e. a “domestic injury.” Id.

Whether this same analysis applies to Florida Civil RICO is a case of

first impression for a district court in Florida. Accordingly, while I concur with

my colleagues that the judgment should be affirmed, I believe a discussion

of the “two-step framework for analyzing extraterritoriality issues” is

warranted.

BACKGROUND

Steve Ferguson appeals a final judgment after a jury trial in the amount

of $131,318,840.47.

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Steve Ferguson v. the Republic of Trinidad and Tobago, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steve-ferguson-v-the-republic-of-trinidad-and-tobago-fladistctapp-2025.