Reliance Wholesale, Inc. v. Godfrey
51 So. 3d 561
| Fla. Dist. Ct. App. | 2010Background
- Reliance sued Godfrey, Minnuto, and Allied for breach of 2005 and 2008 non-compete, non-solicit, and non-disclosure agreements; seeks injunctive relief and damages.
- Trial court initially denied injunctive relief; Renewed Motion for Temporary Injunction was heard Aug. 31, 2009.
- Trial court found 2005 Agreement valid, assets like Reliance’s database and customer relationships constituted legitimate interests; Godfrey’s departure to Allied followed.
- Court credited Reliance’s evidence of a valuable confidential database and substantial relationships with customers as basis for enforcement.
- Trial court concluded Godfrey’s prior-breach defense defeated likelihood of success under the non-compete; court found issues of irreparable harm and remedy at law not proven for injunction.
- Third District reversed, holding Reliance showed likelihood of success and legitimate interests; remanded for entry of temporary injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reliance proved likelihood of success and legitimate business interests | Reliance showed two legitimate interests (confidential information; customer relationships) | Godfrey argued prior breach defense defeated enforceability | Yes; Reliance established two legitimate interests and likelihood of success |
| Whether Godfrey’s prior breach defense invalidates the injunction | Reliance argues defense does not negate independent covenants | Godfrey argues prior employer breach excuses performance | No; defense not viable; covenants are independent |
| Whether irreparable harm presumption and remedy at law defeat injunction | Reliance maintains presumption of irreparable harm supports injunction | Godfrey contends remedy at law is adequate | Irreparable harm presumption remains; injunction proper due to enforceable covenants |
| Whether standing issue was properly before the court | N/A | Standing raised on appeal, not below | Standing issue not properly before appellate court; not considered on the merits |
Key Cases Cited
- Cordis Corp. v. Prooslin, 482 So.2d 486 (Fla. 3d DCA 1986) (temporary injunction standards; injunctive relief as drastic remedy; four-part test)
- Capraro v. Lanier Bus. Prods., Inc., 445 So.2d 719 (Fla. 4th DCA 1984) (dependent covenants rule; prior breach relevance to injunctions)
- Miller Mechanical, Inc. v. Ruth, 300 So.2d 11 (Fla. 1974) (treating non-compete breaches; injunctive relief favored)
- U.S. Floral Corp. v. Salazar, 475 So.2d 1305 (Fla. 3d DCA 1985) (entry of temporary injunction as favored remedy)
- Maynard v. Fla. Bd. of Educ. ex rel. Univ. of S. Fla., 998 So.2d 1201 (Fla. 2d DCA 2009) (standing cannot be raised for first time on appeal)