Chevaldina v. R.K./FL Management, Inc., 133 So. 3d 1086

Raanan Katz and RK Associates own/manage commercial properties in South Florida; Chevaldinas were former RK tenants unhappy with them.
APs filed multiple defamation, tortious interference, and related claims stemming from anonymous blog activity about RK and Katz.
In 2009–2010, Chevaldinas’ prior lease/defamation cases were dismissed with prejudice.
In 2011, an anonymous blog about RK/Katz surfaced; discovery identified Irina Chevaldina as the blogger.
The appellees filed suit in circuit court and obtained a temporary injunction prohibiting defamatory blogs, tortious interference, and trespass; the order is now on appeal.
The appellate court reverses the injunction, concluding the record lacks substantial evidence and the injunction is overbroad and unsupported by the facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the injunction may restrain defamatory speech and tortious interference	Chevaldina argues the injunction impermissibly restricts speech and requires evidence of interference.	Katz contends the injunction is warranted to prevent irreparable harm and protect business relations.	Injunction reversed for lack of proof of interference and overbreadth.
Whether there was irreparable harm justifying a temporary injunction	Plaintiffs rely on potential harm from blogs affecting business.	Record failed to show deleterious impact on specific business relationships.	No sufficient evidence of irreparable harm; injunction improper.
Whether the injunction as drafted is overly broad and First Amendment improper	Injunction sweeps broadly across speech and future defamation.	No specific tailoring of relief to protect concrete interests.	Overbroad; violates First Amendment principles.
Whether stalking and trespass injunctions were properly supported	Blogs constitute cyber-stalking warranting relief.	Evidence did not establish specific incidents of stalking or imminent danger.	Lack of specific incidents/causation; no temporary injunction for stalking or trespass.
Whether the court failed to make required factual findings	Order lacked explicit factual findings supporting relief.	Record shows basis for relief under applicable standards.	Rule 1.610 findings missing; reversal appropriate.

Zimmerman v. D.C.A. at Welleby, Inc., 505 So.2d 1371 (Fla. 4th DCA 1987) (defamatory speech exceptions to injunctions for tortious interference)
Murtagh v. Hurley, 40 So.3d 62 (Fla. 2d DCA 2010) (defamation and ongoing business relationships; need showing of deleterious effect)
Ethan Allen, Inc. v. Georgetown Manor, Inc., 647 So.2d 812 (Fla. 1995) (tortious interference requires concrete evidence of impact on relations)
Angelino v. Santa Barbara Enters., 2 So.3d 1100 (Fla. 3d DCA 2009) (injunctions must include specific factual findings)
City of Miami Beach v. Kuoni Destination Mgmt., Inc., 81 So.3d 530 (Fla. 3d DCA 2012) (multifactor test for temporary injunctions; public interest consideration)
DeRitis v. AHZ Corp., 444 So.2d 93 (Fla. 4th DCA 1984) (injunctions not to exceed scope necessary to relief)
Vrasic v. Leibel, 106 So.3d 485 (Fla. 4th DCA 2013) (speech-related injunctions raise First Amendment concerns)