Rental manager stole 22,000-customer database while still on payroll

The manager immediately contacted Schumacher Automotive, which was setting up its own rental arm, Auto Rentals of the Palm Beaches. He was hired in August 2015 but stayed on Napleton’s payroll simultaneously. 

What followed was brazen. Temporary workers copied Napleton’s customer data into Auto Rentals’ system. When customers called Napleton to book, they were placed into Auto Rentals’ cars without being told. Those who queried unfamiliar credit card charges from “Schumacher Chevrolet” were told Napleton was “going through a name change.” 

By February 2016, Auto Rentals had generated $820,000 in business – 80% from former Napleton customers – with no marketing, no website, and no paid staff. Then surveillance footage caught the manager and others entering Napleton’s office after hours, removing reservation cards. He later pleaded guilty to a felony for wrongfully accessing the computer system. 

The trial court found all defendants liable for misappropriation under Florida’s Uniform Trade Secrets Act. Schumacher Automotive and its principals had “reason to know” the customer list was misappropriated, the court held, but their conduct did not meet the higher “willful and malicious” threshold – so no punitive damages or attorney’s fees were awarded against them. 

The appeals court agreed on liability but trimmed the unjust enrichment award from $864,000 to $734,400, finding only 85% of Auto Rentals’ profits were traceable to the stolen list. It also upheld the denial of $6.2 million in “actual loss” damages as too speculative.