Supreme Court of Florida

Planned Parenthood of Greater Orlando, Inc. v. Mmb Properties

February 23, 201742 Fla. L. Weekly Supp. 204

Summary

The court held that a party seeking to modify or dissolve a temporary injunction need not show changed circumstances when the injunction rests on clear legal error or a clear misapprehension of facts. It also held that the temporary injunction against Planned Parenthood was unsupported by competent, substantial evidence because the trial court mischaracterized the record and granted relief not requested. The court quashed the relevant portion of the district court decision and remanded for permanent-injunction proceedings. Justice Canady, dissenting, would have discharged the case because the changed-circumstances issue was not properly presented to or decided by the district court.