Midnight Express Power Boats, Inc. v. Victor Raul Aguilar

CourtDistrict Court of Appeal of Florida
DecidedMarch 20, 2024
Docket2023-0882
StatusPublished

This text of Midnight Express Power Boats, Inc. v. Victor Raul Aguilar (Midnight Express Power Boats, Inc. v. Victor Raul Aguilar) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Midnight Express Power Boats, Inc. v. Victor Raul Aguilar, (Fla. Ct. App. 2024).

Opinion

Third District Court of Appeal State of Florida

Opinion filed March 20, 2024. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-0882 Lower Tribunal No. 22-20155 ________________

Midnight Express Power Boats, Inc., Appellant,

vs.

Victor Raul Aguilar, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Barbara Areces, Judge.

Cullin O’Brien Law, P.A., and Cullin O’Brien (Fort Lauderdale), for appellant.

Brown Sims, P.C., and Cody L. Frank (Miramar), for appellee SeaVee Boats.

Before EMAS, SCALES and LOBREE, JJ.

SCALES, J. Appellant Midnight Express Power Boats, Inc. (“Midnight”) appeals a

May 2, 2023 order denying Midnight’s motion to intervene as a party

defendant in an injunction action brought by appellee Ram Investments of

South Florida, Inc. (“Ram”) against Ram’s former employee, Victor Aguilar

(“Aguilar”). Based on the facts and circumstances presented in this case and

notwithstanding a default having been entered against Aguilar, we reverse

because Midnight should have been allowed to intervene in the injunction

proceedings.

I. Relevant Background

In 2014, Ram, a boat manufacturer, hired and trained Aguilar as a

laminator. During Aguilar’s approximately eight years of employment with

Ram, he rose to a supervisory position. In November 2018, Ram required

several of its employees, including Aguilar, to sign a Confidentiality, Non-

Disclosure and Non-Competition Agreement (“Agreement”). At issue in this

case is the Agreement’s non-competition provision which reads, in relevant

part, as follows:

The Employee, during the term of this agreement and for a period of one (1) year from the last date Employee provides services to [Ram] . . . shall not directly or indirectly . . . anywhere within the territory of Miami-Dade County, and Broward County, Florida . . . [c]onduct competitive business or work for anyone whom [sic] conducts competitive business, with any of the past or current clients of [Ram], or clients acquired during employee’s tenure.

2 [Ram’s] business entails design, manufacture and sale of water vessels and related products.

In July 2022, Aguilar left Ram’s employ and began working for

SeaHunter Boats, whom Ram alleges is one of its direct competitors. Ram

filed the instant lawsuit against Aguilar seeking to enjoin Aguilar from working

(i) specifically for SeaHunter, and (ii) more generally, with or for a competitor

of Ram within the restricted geographic area outlined in the Agreement.

SeaHunter was identified, but was not named as a defendant, in Ram’s

complaint.

Aguilar was served with Ram’s complaint on November 11, 2022, and,

because Aguilar filed no responsive paper or pleading, a clerk’s default was

entered against Aguilar on December 14, 2022. Shortly thereafter, on

December 20, 2022, Ram filed an ex parte Motion for Temporary Injunction

in which it sought the same injunctive relief it sought in its verified complaint.1

Ram’s ex parte motion was accompanied by an affidavit from Ralph Torres,

one of Ram’s owners. Apparently, after learning of Ram’s complaint,

SeaHunter terminated Aguilar.

1 In that portion of its ex parte motion seeking injunctive relief, Ram sought to enjoin Aguilar from working for “Invincible Boats.” Presumably, this was a typographical error because, in other parts of the motion, Ram asserts, consistent with its verified complaint, that Aguilar was in violation of the Agreement based on Aguilar’s employment with SeaHunter.

3 On January 9, 2023, Ram filed a supplemental affidavit of Torres

asserting that Aguilar “left his employment with SeaHunter and recently

began employment with” Midnight. With regard to Midnight, the supplemental

affidavit asserted that “Midnight . . . produces and manufactures center

console vessels whose appearance is similar to that of [Ram]. Midnight . . .

offers similar options, models, and styles to those of [Ram]. [Ram] and

Midnight compete for the same consumer. Midnight . . . is a direct competitor

of [Ram].” Ram did not seek to amend its verified complaint to identify

Midnight as Aguilar’s employer, nor did Ram file an amended ex parte

injunction motion seeking to enjoin Aguilar from working for Midnight, nor did

Ram notify Midnight that it sought to enjoin Aguilar from working for Midnight.

Three days later, on January 12, 2023, the trial court conducted a

Zoom hearing on Ram’s ex parte injunction motion. At the hearing, Torres

testified that Midnight was a competitor of Ram. After stating that “we have

a default already,” the trial court orally granted Ram’s injunction motion.2

Counsel for Ram then stated: “We’re going to send a letter and a copy

of Your Honor’s order to Midnight and they can govern themselves. If they

2 Prior to adjourning the hearing, the trial court, instructing Ram’s counsel on what to include in the written injunction order, again emphasized the importance of the default on its ruling: “Include in the order though that there has been a default as well entered because I think that’s also a main issue here. It’s basically, everything has been admitted. . . .”

4 feel that they’re not competing, we’ll hear from them. If they feel they’re

competing, I’m sure they’re going to let Mr. Aguilar go.”

Later that day, the trial court entered its written injunction order

enjoining Aguilar from working for “anyone who conducts competitive

business” with Ram. The injunction order, though, further makes the specific

factual finding that Midnight, where Aguilar “is presently working,” is a

“competitor[] of [Ram] and vie[s] for the same market share” as [Ram].3

Upon being made aware of the injunction order, Midnight filed its

February 1, 2023 motion seeking to intervene in the proceedings to establish

that Midnight and Ram are not “competitors” for the purpose of the

Agreement and similar agreements that Ram has with other individuals.

After conducting an April 26, 2023 hearing, the trial court entered the

order on appeal denying Midnight’s intervention motion. The order states:

“The non-party is, in essence, requesting that this Court reconsider its prior

ruling on a temporary injunction of a defaulted defendant. This is not an issue

that is subordinate to the claims in this cause.”

It is from this order that Midnight timely appeals.

3 Notwithstanding the language contained in the relevant provision of the Agreement, no evidence was presented, nor were any findings made by the trial court, regarding “past or current clients of [Ram] or clients acquired during [Aguilar’s] tenure.”

5 II. Analysis4

Intervention is governed by Florida Rule of Civil Procedure 1.230,

which reads in its entirety, as follows:

Anyone claiming an interest in pending litigation may at any time be permitted to assert a right by intervention, but the intervention shall be in subordination to, and in recognition of, the propriety of the main proceeding, unless otherwise ordered by the court in its discretion.

Fla. R. Civ. P. 1.230.

The trial court concluded that intervention was not appropriate because

Midnight sought to have the court revisit its injunction order, and that such a

claim somehow was not subordinate to Ram’s principal claim seeking to

enjoin Aguilar from working for Midnight.

This was error. Plainly, Midnight had an interest in the litigation

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Midnight Express Power Boats, Inc. v. Victor Raul Aguilar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/midnight-express-power-boats-inc-v-victor-raul-aguilar-fladistctapp-2024.