Joe Carollo, a Miami city commissioner, sued political opponents and others under the First Amendment and related theories after they criticized his conduct and campaign activities. The district court denied the defendants’ motion to dismiss. The Eleventh Circuit affirmed some rulings, but reversed the dismissal-stage ruling on Carollo’s First Amendment retaliation claim. The court applied the distinction between speech made pursuant to official duties and speech made as a private citizen, and concluded that the complaint plausibly alleged protected speech and retaliatory conduct for at least part of the claim. The defendants’ status as public officials did not eliminate the constitutional question, and the qualified-immunity issue could not be resolved on the pleadings because the record and allegations required further development. The court also identified other pleading defects and left those portions of the dismissal intact. It remanded with instructions to allow Carollo to amend his complaint and proceed to discovery on the surviving theory. The disposition was affirmed in part, reversed in part, and remanded.