Background
Miami Dade Smart Lighting Partners, LLC appealed a non-final order entered by the Circuit Court for Miami-Dade County in litigation against Miami-Dade County. The brief per curiam opinion does not describe the underlying dispute or specify the relief granted or denied by the circuit court.
The appeal concerned temporary-injunction standards. Under Florida law, a party seeking that extraordinary relief must establish a substantial likelihood of success on the merits, the absence of an adequate legal remedy, irreparable harm without an injunction, and consistency with the public interest.
The Court’s Holding
The Third District Court of Appeal affirmed the circuit court’s non-final order without additional factual analysis. Because the opinion consists of a summary affirmance supported by citations to temporary-injunction precedent, it does not identify which required element or elements were dispositive.
The court emphasized through its cited authorities that the party seeking an injunction must prove every required element with competent, substantial evidence. A substantial likelihood of success requires good reasons to anticipate success on the merits; merely presenting a colorable claim is insufficient.
Key Takeaways
- A temporary injunction is extraordinary relief requiring proof of all four established elements.
- Each element must be supported by competent, substantial evidence.
- A merely colorable claim does not establish a substantial likelihood of success on the merits.
Why It Matters
The decision reinforces the demanding evidentiary burden imposed on parties seeking temporary injunctions in Florida. Although the opinion provides no detailed application to the parties’ dispute, its affirmance underscores that failure to establish any required element can prevent temporary injunctive relief.