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LTC 505-2023 Appellate Court Victory in Amnesia International, LLC dba Story Nightclub v. City of Miami BeachMIAMI BEACH OFFICE OF THE CITY ATTORNEY LTC No. _505-2023______ _ LETTER TO COMMISSION TO: Mayor Dan Gelber and Members of the City Commission FROM: DATE: Rafael A Paz, City Attorney � November 13, 2023 SUBJECT: Appellate Court Victory in Amnesia International, LLC d/bla Story Nightclub v. City of Miami Beach This letter is to advise you of our recent appellate court victory, in which Florida's Third District Court of Appeal affirmed the City's trial court win relating to enforcement of the 2:00 a.m. rollback of alcohol hours in the South of Fifth neighborhood, a measure which was sponsored by Commissioner Laura Dominguez earlier this year, and approved by the City Commission on a 5/7ths vote in an effort to protect residents' quality of life. The opinion, published as Amnesia Int'/, LLC v. City of Miami Beach, No. 3023-0459, 2023 WL 7006781 (Fla. 3d DCA 2023), agreed with the trial court's well-reasoned order, which found that the 2:00 a.m. alcohol hours rollback for establishments with live entertainment and/or occupancy of 100 people or more served a legitimate public interest and was rationally related to that purpose. I am also pleased to report that on November 11, 2023, the Plaintiff voluntarily dismissed its case rather than seek any further relief from the court. This means that the entire lawsuit is now over, thereby bringing this matter to a successful conclusion in favor of the City, and ending any uncertainty regarding the legal status of the 2 a.m. rollback in the South of Fifth residential neighborhood. The legal team was assisted by many members of the Administration, including Planning Director Thomas Mooney, who testified at the evidentiary hearing, as well as personnel from Code Compliance and the Miami Beach Police Department, who provided critical evidence. I also personally testified at the hearing to help explain the City Commission's rationale for enacting the Ordinance. A copy of the Third District Court of Appeal's October 25th decision is attached. We are pleased to have defended the City Commission's decision to enact the Ordinance and to protect City residents' quality of life. As always, please feel free to contact me or Rob Rosenwald for further information about this or any City litjgation matter. We are committed to providing excellent public service and safety to all who live, work, and play in our vibrant, tropical, historic community. Third District Court of Appeal State of Florida Opinion filed October 25, 2023. Not final until disposition of timely filed motion for rehearing. ________________ No. 3D23-0459 Lower Tribunal No. 23-3316 ________________ Amnesia International, LLC, etc., Appellant, vs. City of Miami Beach, etc., Appellee. An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Reemberto Diaz, Judge. Burstyn Law PLLC, and Sean A. Burstyn; Crabtree & Auslander, Charles M. Auslander, John G. Crabtree, Linda Ann Wells, and Brian C. Tackenberg, for appellant. Rafael A. Paz, City Attorney, Robert F. Rosenwald, Jr., Chief Deputy City Attorney, and Freddi R. Mack, Senior Assistant City Attorney; Weiss Serota Helfman Cole & Bierman, P.L., and Edward G. Guedes, Joseph H. Serota, Eric P. Hockman, and Lindsay M. Behnke, for appellee. Before EMAS, MILLER and LOBREE, JJ. EMAS, J. 2 Amnesia International, LLC, d/b/a Story Nightclub, appeals an order denying its motion seeking a temporary injunction to prevent enforcement of City of Miami Beach ordinance 2023-4542, which prohibits, with some exceptions, the sale of alcohol after 2 a.m. at establishments south of Fifth Street.1 Following an evidentiary hearing, the trial court denied Amnesia’s motion for temporary injunction. “‘The standard of review of trial court orders on requests for temporary injunction is a hybrid. To the extent the trial court’s order is based on factual findings, we will not reverse unless the trial court abused its discretion; however, any legal conclusions are subject to de novo review.’” Law Offices of Kravitz & Guerra, P.A. v. Brannon, 338 So. 3d 1022, 1023 (Fla. 3d DCA 2022) (quoting Quirch Foods LLC v. Broce, 314 So. 3d 327, 337 (Fla. 3d DCA 2020) (additional citations omitted)). Upon our review of the record, and applying the above-described hybrid standard of review, there is competent substantial evidence to support the trial court’s order. We find neither an abuse of discretion in the trial court’s decision to deny the motion for temporary injunction, nor any error in its attendant legal conclusions. See Fla. Dep’t of Health v. Florigrown, LLC, 1 We have jurisdiction. See Fla. R. App. P. 9.130(a)(3)(B) (authorizing appellate review of nonfinal orders that “grant, continue, modify, deny, or dissolve injunctions, or refuse to modify or dissolve injunctions.”) 3 317 So. 3d 1101, 1110-11 (Fla. 2021) (“A temporary injunction is extraordinary relief that should be granted only when the party seeking the injunction has established four elements: (1) a substantial likelihood of success on the merits, (2) the unavailability of an adequate remedy at law, (3) irreparable harm absent entry of an injunction, and (4) that the injunction would serve the public interest. . . . [A] movant’s failure to establish any single element means that the injunction must be denied”) (citing Provident Mgmt. Corp. v. City of Treasure Island, 796 So. 2d 481, 485 (Fla. 2001) (extraordinary relief) and Reform Party of Fla. v. Black, 885 So. 2d 303, 305 (Fla. 2004) (elements of a claim for a temporary injunction). Affirmed.