Planned Parenthood of Greater Orlando, Inc., etc. v. MMB Properties, etc.

The conflict issue presented in this case involves the standard for modifying or dissolving a temporary injunction. The Fifth District Court of Appeal “acknowledge^] conflict with the Third and Fourth Dis-trictfs]” as to whether a party moving to modify or dissolve a temporary injunction must establish “changed circumstances.” Planned Parenthood of Greater Orlando v. MMB Properties, 171 So.3d 125, 128 & n.3 (Fla. 5th DCA 2015).1 We conclude that requiring a party to meet the burden of proving changed circumstances even when a party shows clear misapprehension of the facts or clear legal error…