A wedding venue that asked a court to stop its neighbors’ gunfire, chainsaws and airboat engines during ceremonies did not prove the irreparable harm needed for a temporary injunction, the Sixth District Court of Appeal held on October 30, 2026. In Hatcher v. Restorical, LLC, No. 6D2025-3091, Judge Gannam wrote for the court. Judge Stargel concurred, and Judge Mize concurred with an opinion. The court reversed the injunction and remanded. The opinion is not final until any timely rehearing motion is decided.
The dispute
Restorical, LLC owns the historic Sydonie Mansion in Mount Dora, where it hosts weddings and other events and where its owners also live. At the time of suit it had hosted weddings for around nine years, averaging two to three per week during its September-to-May busy season. Its neighbors, Bradley and Audrey Hatcher, keep dogs, boats, motor vehicles and a shooting range. Restorical alleged that the Hatchers intentionally disrupted weddings in 2025 with loud gunfire and revving chainsaw and airboat engines, and sued for private nuisance.
After an evidentiary hearing, the Orange County trial court granted a temporary injunction. It found Restorical likely to succeed on its nuisance claim and found the injuries “irreparable and not adequately compensable by monetary damages,” threatening “the loss of goodwill and the viability of the venue.” The order barred the Hatchers from disrupting events and required Restorical to give them 24 hours’ written notice of its events.
The holding
The Sixth District addressed only irreparable harm and inadequate remedy at law, which it treated together as “two sides of the same coin.” It reviewed three ways Florida courts have found irreparable harm: damages that cannot be quantified, the total destruction of a business, and harm that recurs so often that a multiplicity of suits would be needed. It also noted that “the loss of some business, without more, is not irreparable harm.”
Restorical met none of them, the court said. There was credible testimony that the owner feared losing business and the mansion itself. But there was “no testimony or other evidence of cancelations or lost bookings,” and no evidence “as to why any actual loss of business would not be quantifiable given Restorical’s nine-year track record of events.” Restorical was still booking weddings. The one partial refund of a single wedding fee was calculable, and nothing showed refunds would recur.
The court was careful about what it was saying. “There was competent, substantial evidence to support a finding that the Hatchers’ conduct is a harmful nuisance, but the harm is not self-evidently irreparable, and Restorical did not prove its irreparability.” It added: “This is not to say Restorical cannot prove irreparable harm.”
What the court did not decide
A footnote said the trial court had relied on Gartman v. Southern Tactical Range, LLC (Fla. 1st DCA 2025), which held the shooting-range noise immunity in section 823.16 unconstitutional. That decision is under review in the Florida Supreme Court (No. SC2025-1259, argued May 7, 2026), and the Sixth District did not reach the statute. In another footnote, it left open whether the Evidence Code’s hearsay rules apply at a contested temporary-injunction hearing, because the Hatchers did not object to post-hearing affidavits and the issue was not preserved.
The concurrence
Judge Mize wrote separately to say there is “tension” in Florida cases: courts say harm is irreparable only if money cannot compensate it, yet some say the destruction of a business is enough. He wrote that any rule that destruction of a business alone suffices, “without any requirement that the value of the business be incalculable, . . . must be wrong.” He said the tension did not need resolving here because there was no evidence the business would be destroyed.
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