REV RECREATION GROUP, INC. & GENERAL RV CENTER, INC. v. LDRV HOLDINGS CORP.
259 So. 3d 232
Fla. Dist. Ct. App.2018Background
- REV (manufacturer) contracted with General RV to sell two models (Signature, Marquis) after previously contracting with Lazydays to sell other models (Diplomat, Dynasty); Lazydays claimed the models were the same "line-make."
- Lazydays sued REV (and later added General RV) under Florida statutes governing RV manufacturer/dealer relationships (secs. 320.3201-.3211) and common-law theories, seeking a temporary injunction days before an industry supershow.
- Trial court held evidentiary hearings and found Lazydays likely to succeed on the merits and that the models shared statutory "line-make" characteristics; it entered a 30-day injunction preventing REV/General RV from selling the disputed models outside Lazydays, later extended "until further order."
- The trial court conflicted in its reasoning, suggesting both that the models were the same line-make under the statute and that no statutory violation appeared; it characterized the injunction as an equitable contract-based remedy and initially set a $40,000 bond, later raising it to $1 million.
- The Second District reviewed the injunction de novo for legal issues and for abuse of discretion as to factual findings, concluded Lazydays made a sufficient preliminary showing under section 320.3203(2) that REV contracted to sell the same line-make through a competitor, and affirmed the injunction.
- The panel reversed only the bond requirement because section 320.3210(3) expressly provides that such injunctions "shall be issued without bond," removing the court's discretion to impose one.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether models at issue constitute the same "line-make" under §320.3202(6) | Lazydays: the models meet the five statutory criteria and are the same line-make, so exclusivity bars REV from selling them through General RV | REV/General RV: model names/industry usage distinguish different line-makes; alternate definitions (DMV practice or contract "product line") should control | Court: applied the statutory definition §320.3202(6); found record support that models are the same line-make and affirmed injunction |
| Whether a temporary injunction was proper to prevent REV/General RV from selling the disputed models | Lazydays: showed likelihood of success, irreparable harm to reputation, and need to maintain status quo before trial | REV/General RV: argued insufficient showing under injunction standards and that statutory remedies did not apply as claimed | Court: factual findings support issuance; injunction upheld though trial court's legal reasoning was inconsistent |
| Whether the trial court erred by relying on common-law equitable grounds instead of the statute | Lazydays: statutory injunctive remedy is available and governing | REV/General RV: trial court questioned statutory application; sought dissolution | Court: trial court should have applied statutes directly; applying statute was required but result (injunction) stands because findings support statutory remedy |
| Whether the trial court could require an injunction bond | Lazydays: injunction under §320.3210(3) must be issued without bond | REV/General RV: consented to bond argument below; trial court imposed $1M bond | Court: reversed bond requirement—§320.3210(3) mandates issuance without bond; remanded to strike bond |
Key Cases Cited
- Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017) (standard of review for temporary injunctions: factual findings abuse-of-discretion, legal conclusions de novo)
- Atomic Tattoos, LLC v. Morgan, 45 So. 3d 63 (Fla. 2d DCA 2010) (trial court's injunction ruling presumed correct; heavy burden to show abuse of discretion)
- Marsicano v. Rogers, 164 So. 2d 531 (Fla. 2d DCA 1964) (appellate courts should read and harmonize trial court findings with the record)
- Dade Cty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638 (Fla. 1999) (a correct result will be upheld even if the trial court stated wrong reasons when record supports judgment)
- Townsend v. R.J. Reynolds Tobacco Co., 192 So. 3d 1223 (Fla. 2016) (statutory "shall" construed as mandatory)
- Medco, LLC v. Bailey, 152 So. 3d 105 (Fla. 2d DCA 2014) (reversal warranted where trial court's factual findings supported a statutory presumption that the court failed to apply)