JEEP CORPORATION, ET AL., APPELLANTS,
v.
LINDA G. SANDERS, ET AL., APPELLEES
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Jeep Corporation and AMC obtained an Ohio injunction preventing an ex-employee from testifying against them in litigation. When that employee was called as a witness in a Florida product liability case, the Florida trial court enjoined AMC from enforcing the Ohio injunction. The appellate court reversed, holding that principles of comity and equitable restraint require respecting valid out-of-state injunctions when no irreparable harm would result.
No. The trial court's order enjoining AMC from enforcing the Ohio injunction and directing AMC to allow Huffstutler to testify in violation of that injunction was reversed because principles of comity require respecting valid judicial acts of other states, and the plaintiff could secure other expert testimony and would not suffer irreparable harm.
[1] Judicial acts of courts in other states should be respected under the comity doctrine where not inconsistent with the public policy interests of the forum state.
[2] An injunction should not be issued unless there is a showing of irreparable harm.
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Join FLexlaw to unlock all legal intelligence“Where not inconsistent with public policy interests of the State of Florida, the judicial acts of courts in other states, properly exercising their jurisdiction, should be respected under the comity doctrine.”
Establishes the governing principle that Florida courts should respect valid out-of-state judicial decisions absent public policy concerns.
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Join FLexlaw to unlock all legal intelligenceAMC obtained an injunction in Ohio against ex-employee Huffstutler prohibiting him from assisting, consulting with, or testifying in claims against AM…
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COWART, Judge.
Appellant, Jeep Corporation and American Motors Corporation (AMC), obtained an injunction in Ohio enjoining an ex-employee (Huffstutler) from assisting, consulting with or testifying for, persons making claims against or litigating with AMC involving Jeep C-J vehicles. Sanders, appel-lees-plaintiffs, sued AMC in Florida involving a Jeep C-J vehicle, and gave notice that Huffstutler would testify for the plaintiffs. AMC asserted the Ohio injunction, and the trial judge in the Florida case entered an order directing AMC to allow Huffstutler to testify in the Florida case and further enjoining AMC from seeking sanctions in the Ohio court as a result of Huffstutler’s violation of the Ohio injunction. AMC appeals. We reverse.
Under principles of comity and equitable principles relating to the issuance of injunctions, we reverse the trial court order enjoining AMC from enforcing the injunction it obtained against Huffstutler in Ohio and the order directing AMC to allow Huffstutler to testify in Florida in violation of the Ohio injunction.1 Where not inconsistent with public policy interests of the State of Florida, the judicial acts of courts in other states, properly exercising their jurisdiction, should be respected under the comity doctrine. Further, injunctions should not issue except in cases of irreparable harm. Sanders, the plaintiff in Florida, can secure other expert testimony and will not be irreparably harmed by not being able to use Huffstutler as an expert in violation of the Ohio injunction, unless Huffstutler is a unique expert witness because of his prior relationship to AMC which was the very reason for the Ohio injunction.
The trial court order directing AMC to allow Huffstutler to testify in Florida and enjoining AMC from seeking sanctions in Ohio against Huffstutler for violation of the Ohio injunction is
REVERSED.
ORFINGER and GOSHORN, JJ., concur. . See, e.g., Roberts Realty of Bahamas, Ltd. v. Miller & Solomon (Bahamas), Ltd., 234 So. 2d 417, (Fla. 3d DCA 1970); Groff GMC Trucks v. Driggers, 101 So. 2d 58 (Fla. 1st DCA 1958); 43A C.J.S. Injunctions, § 59 p. 48-49 (1978).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Packaging Corp. OF Am. v. DeRYCKE, 49 So. 3d 286 (Fla. 2d DCA 2010)…h Carolina court accommodated him. “[JJudicial acts of courts in other states, properly exercising their jurisdiction, should be respected under the comity doctrine” where not inconsistent with Florida public policy interests. Jeep Corp. v. Sanders, 546 So. 2d 1098, 1099 (Fla. 5th DCA 1989) (reversing, on comity grounds, trial court’s order directing American Motors Corporation to allow ex-employee to testify for plaintiffs in suit against Jeep despite Ohio injunction precluding ex-employee from testifying).…
Authorities Cited
- Groff G.M.C. Trucks, Inc. v. Driggers, 101 So. 2d 58 (Fla. 1st DCA 1958)
- Roberts Realty OF the Bahamas, Ltd. v. Miller & Solomon (Bahamas), Ltd., 234 So. 2d 417 (Fla. 3d DCA 1970)