Moon et al v. Medical Technology Associates, Inc.

Eleventh Circuit Order Vacating Preliminary Injunction & Remanding

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The case involves a non-compete dispute between two competitors in the medical gas industry, the Moon family and Medical Technology Associates. The Moons previously worked for MTA and entered employment agreements with MTA that contained certain restrictive covenants. Upon their separation from MTA, the Moons launched their own competing medical gas venture and sued MTA for a declaratory judgment holding that the restrictive covenants at issue were unenforceable. MTA counter-sued, alleging that the Moons were in violation of their respective agreements. MTA then sought a preliminary injunction.

The parties submitted various conflicting affidavits related to the motion for a preliminary injunction. The Plaintiffs moved for an evidentiary hearing on the motion. The District Court denied the motion, but held a non-evidentiary oral argument on the motion. After the oral argument, the District Court issued an order granting MTA a sweeping preliminary injunction. The District Court's order was noteworthy in that it was substantially identical to the proposed order submitted by MTA. That order cited no case law and cited none of the facts put forward by the Moons.

In reversing the District Court's order, the Eleventh Circuit reiterated several important points of law: First, where there is a legitimate dispute over material facts, a preliminary injunction cannot be granted without an evidentiary hearing. Second, in the Eleventh Circuit a preliminary injunction is an extraordinary and drastic remedy, and the movant bears the burden of persuasion as to every element. Finally, the holdings of intermediate state appellate courts are binding on the federal courts absent persuasive evidence that the highest state court would rule otherwise.

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Reference Info:Decision | Federal, 11th Circuit | United States


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