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Airport Executive Towers v. CIG Realty, Inc.

Citations: 716 So. 2d 311; 1998 Fla. App. LEXIS 9579; 1998 WL 422599Docket: 98-1229

Court: District Court of Appeal of Florida; July 29, 1998; Florida; State Appellate Court

Narrative Opinion Summary

In this case, Airport Executive Towers (AET) appealed a temporary injunction favoring CIG Realty, Inc. (CIG), which barred AET from moving net proceeds from a property sale out of Florida. CIG claimed that AET owed money under two nonrecourse notes, triggering liability under specific conditions, though these notes did not grant CIG a security interest in AET's assets. CIG also initiated a breach of contract lawsuit seeking monetary damages against AET. AET's motion to dissolve the injunction was denied by the trial court, prompting an appeal. The appellate court reviewed the injunction criteria, which necessitate demonstrating a substantial likelihood of success, a clear legal right, and potential irreparable harm. The court found CIG did not satisfy these requirements, noting an adequate legal remedy was available through its lawsuit for damages. Furthermore, the court cited Florida law prohibiting pre-judgment asset restrictions in monetary disputes. Consequently, the appellate court reversed the trial court's decision, ordering the dissolution of the temporary injunction.

Legal Issues Addressed

Adequate Legal Remedy in Monetary Disputes

Application: The court determined that CIG had an adequate legal remedy through its breach of contract lawsuit against AET, negating the need for a temporary injunction.

Reasoning: The court found that CIG failed to meet these criteria, noting that it had an adequate legal remedy through its damages lawsuit against AET.

Criteria for Granting Temporary Injunctions

Application: The appellate court assessed whether CIG demonstrated a substantial likelihood of success on the merits, a clear legal right, and the likelihood of irreparable harm to justify the temporary injunction.

Reasoning: The appellate court evaluated the criteria for granting a temporary injunction, which requires demonstrating a substantial likelihood of success on the merits, a clear legal right in the subject matter, and the likelihood of immediate and irreparable harm without the injunction.

Prohibition of Asset Restrictions Prior to Judgment

Application: The appellate court highlighted that established Florida law prohibits courts from imposing restrictions on a defendant's assets before a judgment in a monetary dispute.

Reasoning: The court cited established Florida case law, emphasizing that a court cannot impose restrictions on a defendant's assets prior to judgment in a monetary dispute.