Supreme Court of Florida

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

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

Summary

The Court rejected a categorical changed-circumstances requirement for modifying or dissolving a temporary injunction when the movant demonstrates clear legal error or a clear misapprehension of the facts. It also held that the temporary injunction against Planned Parenthood was unsupported by competent, substantial evidence and improperly included relief that had not been requested. The Court quashed the relevant portion of the district court's decision and remanded for permanent-injunction proceedings. Canady, J., dissenting, would have discharged the case because the asserted conflict issue was not properly presented to or decided by the district court.