Schiller v. Miller
1993 WL 174889, 621 So.2d 481 (1993)
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Rule of Law:
A temporary injunction may be granted to prevent the disposal of personal property if a trial court finds that the property is unique or peculiar and that the plaintiff lacks an adequate remedy at law, such as monetary damages.
Facts:
- During a long-term personal relationship, Paul Miller purchased four pieces of high-value jewelry with his own funds, including a 5.8 carat diamond engagement ring.
- The jewelry was kept in a safe in the home Miller shared with Francine S. Schiller.
- Shortly after their purchase, the pieces were appraised for considerably more than their original price.
- When the relationship ended, Schiller took possession of the jewelry and placed it in a safe deposit box.
- Miller claimed he purchased the jewelry as an investment and only lent it to Schiller to wear.
- Schiller claimed the jewelry was a gift from Miller and belonged to her.
Procedural Posture:
- Paul Miller filed an eight-count complaint against Francine S. Schiller in a Florida trial court, seeking legal and equitable relief.
- The trial court granted Miller's initial request for an ex parte temporary restraining order without notice to Schiller.
- Schiller filed a motion to dissolve the ex parte injunction for failing to comply with procedural rules.
- After an evidentiary hearing, the trial court dissolved the ex parte injunction but entered a new temporary injunction prohibiting Schiller from disposing of the jewelry pending a final judgment.
- Schiller, as appellant, appealed the trial court's order granting the new temporary injunction to the District Court of Appeal of Florida, Fourth District.
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Issue:
Did the trial court abuse its discretion by issuing a temporary injunction to prevent the disposal of high-value jewelry based on findings that the items are unique creations whose market value is difficult to ascertain, thus rendering a legal remedy inadequate?
Opinions:
Majority - Per Curiam
No. The trial court did not abuse its discretion by issuing the injunction because it made specific findings that the property was unique and that the plaintiff lacked an adequate remedy at law. The court defers to the trial court's factual findings that the jewelry items are 'unique one of a kind creations' and that their 'actual present market value... is difficult to ascertain.' These findings provide a sufficient basis to conclude that a legal remedy like monetary damages would be inadequate. Therefore, granting the injunction to maintain the status quo was a proper exercise of the court's discretion.
Dissenting - Farmer, J.
Yes. The trial court abused its discretion because the plaintiff failed to establish the necessary requirements for an injunction regarding personal property. An injunction is only proper if the property is peculiar and money damages are inadequate. Here, Miller himself testified he purchased the jewelry as an 'investment,' which is an 'outright concession that money would be entirely adequate to compensate him.' The trial court incorrectly equated high cost with uniqueness and ignored the plaintiff's own admission that a legal remedy was sufficient, thereby improperly converting a narrow equitable exception into the general rule.
Analysis:
This case illustrates the significant deference appellate courts give to a trial court's factual findings regarding the 'uniqueness' of personal property in injunction proceedings. It highlights the tension between the general rule that injunctions are not available for personalty (because money is an adequate remedy) and the exception for peculiar items. The strong dissent argues that this deference can lead to an erosion of legal principles, allowing equitable remedies where legal ones are clearly sufficient and making the law less predictable. The decision expands the potential for litigants to characterize high-value, but otherwise marketable, goods as 'unique' to secure pre-judgment equitable relief.
