Charlotte County v. Grant Medical Transportation, Inc., 68 So. 3d 920

Grant sued Charlotte County and Ameditrans to enjoin contract negotiations and entry of Ameditrans’ contract.
Ameditrans won the County bid, Grant claimed Ameditrans failed to satisfy bid requirements.
At the time of Grant’s motion for a temporary injunction, negotiations were ongoing and a contract was later finalized.
Grant offered sparse, conclusory allegations of irreparable harm and likelihood of success on the merits.
The trial court granted the injunction; on review, the appellate court reversed due to failure to prove all four elements and inadequate findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the temporary injunction was properly issued.	Grant contends irreparable harm and likelihood of success on the merits.	County and Ameditrans argue no irreparable harm, no likelihood of success, and inadequate findings.	No; injunction reversed due to failure to prove all four elements and insufficient findings.

Naegele Outdoor Adver. Co. v. Naegele, 634 So.2d 750 (Fla. 1st DCA 1994) (findings must go beyond parroting four-prong test)
Snibbe v. Napoleonic Soc'y of Am., Inc., 682 So.2d 568 (Fla. 2d DCA 1996) (four-element test must be supported with specific findings)
Liberty County v. Baxter's Asphalt & Concrete, Inc., 421 So.2d 505 (Fla. 1982) (trial court may waive minor bid irregularities if substantial compliance exists)
Brand v. Elliott, 610 So.2d 37 (Fla. 5th DCA 1992) (counsel argument alone is not evidence for injunction)
Orkin Extermination Co. v. Tfank, 766 So.2d 318 (Fla. 4th DCA 2000) (evidentiary requirements for contested injunction hearings)
Quadomain Condo. Ass'n v. Pomerantz, 341 So.2d 1041 (Fla. 4th DCA 1977) (injunctions focus on timely relief and protectable rights)
City of Coral Springs v. Florida Nat'l Props. Inc., 340 So.2d 1271 (Fla. 4th DCA 1976) (illustrates limits on injunctions in improper contexts)