ROBERT WOHLFELD AND LEYDI WOHLFELD
v.
PORTOFINO TOWERS CONDOMINIUM ASSOCIATION, INC.

Fla. 3d DCA | 2019-11-06
No. 19-0514
44 Fla. L. Weekly D2136 Florida District Court of Appeal, Third District (2019) Positive Treatment
Cited by 1 case

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Synopsis

The appellate court reversed trial court orders granting temporary injunctive relief. The court found the orders were improperly issued without proper notice, an evidentiary hearing, and required findings of fact, as conceded by the appellee.


Holding

No, the temporary injunctive relief orders were improperly granted. The appellee confessed error, acknowledging that the trial court failed to comply with the strict requirements for issuing temporary injunctions.


Headnotes

[1] Temporary injunctive relief may not be granted without proper notice to the parties.

[2] A trial court must conduct an evidentiary hearing before issuing a temporary injunction.

Previewing 2 of 4 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

Key Quotes

“Because temporary injunctions are extraordinary remedies, strict requirements govern their issuance”

Establishes the high standard for issuing temporary injunctions.

Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.

Join FLexlaw to unlock all legal intelligence

Facts & Procedural History

The Wohlfelds appealed trial court orders granting temporary injunctive relief. The appellee conceded that these orders were entered without proper no…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court

EMAS, C.J.

ON CONFESSION OF ERROR Robert and Leydi Wohlfeld appeal from trial court orders rendered on February 11 and 28, 2019. These two orders, which granted temporary injunctive relief,1 were entered by the trial court without proper notice (for at least one of the hearings), without an evidentiary hearing, and without requisite findings of fact. Appellee, Portofino Towers Condominium Association, has confessed error and concedes that it is improper to order temporary injunctive relief without complying with these requirements. See e.g., Fla. R. Civ. P. 1.610(c); City of Miami v. Santos, 44 Fla. L. Weekly D2136 at *1 (Fla. 3d DCA Aug. 21, 2019) (observing that “[b]ecause temporary injunctions are extraordinary remedies, strict requirements govern their issuance” and reversing temporary injunction where there was inadequate notice and the trial court’s order lacked the required findings of facts and statement of legal reasons); Bull Motors, LLC v. Brown, 152 So. 3d 32 (Fla. 3d DCA 2014) (holding trial court’s failure to conduct evidentiary hearing prior to entering injunction violated due process); Chevaldina v. R.K./FL Mgmt., Inc., 133

So. 3d 1086 (Fla. 3d DCA 2014) (reversing injunction order because, inter alia, trial court failed to make factual findings).

We therefore reverse the orders on appeal and remand for further proceedings consistent with this opinion.2

Footnotes
1 Appellee filed a motion to dismiss this appeal, contending that the orders at issue are not in the nature of injunctions, but instead are in the nature of nonappealable case management orders, citing Clevens v. Omni Healthcare, Inc., 83 So. 3d 1011 (Fla. 5th DCA 2012). We denied appellee’s motion to dismiss, and we treat this as an appeal of non-final orders under Florida Rule of Appellate Procedure 9.130(a)(3)(B) (nonfinal orders that “grant, continue, modify, deny, or dissolve injunctions . . . .”)
2 Because we reverse on this basis, we need not and therefore do not reach the merits of the Wohlfelds’ argument that the injunction order violated their right to free speech under Florida and Federal law.

Cases With Similar Vibessemantic neighbors from the corpus


Citator

Cited By

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw