MIAMI DADE SMART LIGHTING PARTNERS, LLC
v.
MIAMI-DADE COUNTY

Fla. 3d DCA | 2026-07-23
No. 2025-2276
Rebull, J., Logue, J., Lindsey, J., Gooden, J.
2026 FL 9400 Florida District Court of Appeal, Third District (2026)

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Holding

A temporary injunction requires proof of four elements: substantial likelihood of success on the merits, unavailability of an adequate remedy at law, irreparable harm absent the injunction, and that the injunction serves the public interest.


Headnotes

[1] A party seeking a temporary injunction must establish with competent, substantial evidence all four elements: substantial likelihood of success on the merits, unavailabil…

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Key Quotes

“A temporary injunction is extraordinary relief that should be granted only when the party seeking the injunction has established four elements: (1) a substantial likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3) irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public interest.”

Statement of the legal standard for temporary injunctions under Florida law

Facts & Procedural History

Miami Dade Smart Lighting Partners, LLC sought a temporary injunction against Miami-Dade County. The trial court denied the injunction.…

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Opinion of the Court

Third District Court of Appeal

State of Florida

Opinion filed July 23, 2026.

Not final until disposition of timely filed motion for rehearing.

No. 3D25-2276

Lower Tribunal No. 25-13527-CA-01 Miami Dade Smart Lighting Partners, LLC,

Appellant,

vs.

Miami-Dade County,

Appellee.

An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Thomas J. Rebull, Judge.

VLP Copenhaver Espino, and Michael Albert Piscitelli, Jennifer Carmen Gonzalez, and Kristen Michaela Jimenez (Fort Lauderdale), for appellant.

Geraldine Bonzon-Keenan, Miami-Dade County Attorney, and Bruce Libhaber, Dale Patrick St. Elmo Clarke, and Brianna Elizabeth Donet, Assistant County Attorneys, for appellee.

Before LOGUE, LINDSEY and GOODEN, JJ.

PER CURIAM.

Affirmed. See Florida Dep't of Health v. Florigrown, LLC, 317 So. 3d 1101, 1110 (Fla. 2021) (“A temporary injunction is extraordinary relief that should be granted only when the party seeking the injunction has established four elements: (1) a substantial likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3) irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public interest."); Telemundo Media, LLC v. Mintz, 194 So. 3d 434, 435–36 (Fla. 3d DCA 2016) (“The party seeking an injunction must satisfy each element with competent, substantial evidence.”); City of Jacksonville v. Naegele Outdoor Advert. Co., 634 So. 2d 750, 753 (Fla. 1st DCA 1994) (“A substantial likelihood of success on the merits is shown if good reasons for anticipating that result are demonstrated. It is not enough that a merely colorable claim is advanced.").

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