Preliminary Injunction – Court Error

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7^th Circuit Court of Appeals

Case Name: Mary B. Valencia, et al. v. City of Springfield, Illinois

Case No.: 17-2773

Officials: FLAUM, EASTERBROOK, and MANION, Circuit Judges.

Focus: Preliminary Injunction – Court Error

Plaintiffs allege the City of Springfield (“Springfield” or “the City”) unlawfully discriminated against three disabled individuals when it ruled they could no longer occupy a single-family residence located within 600 feet of an existing disabled group home. Finding that plaintiffs possessed a reasonable likelihood of success on the merits, the district court granted them a preliminary injunction and enjoined the City from initiating eviction proceedings while this case is pending. The City appeals. For the reasons stated below, we affirm.

The City contests only a single aspect of the preliminary injunction inquiry: whether plaintiffs are likely to succeed on the merits. In reviewing the grant or denial of a preliminary injunction, this court “examines legal conclusions de novo, findings of fact for clear error, and the balancing of harms for abuse of discretion.” Coronado v. Valleyview Pub. Sch. Dist. 365-U, 537 F.3d 791, 795 (7th Cir. 2008); see also Whitaker, 858 F.3d at 1044. In other words, “[a] district court abuses its discretion when, in conducting its preliminary injunction analysis, it commits a clear error of fact or an error of law.” Girl Scouts, 549 F.3d at 1086. “Absent such errors, we accord a district court’s decisions during the balancing phase of the analysis great deference.” Id.; see also Turnell v. CentiMark Corp., 796 F.3d 656, 662 (7th Cir. 2015) (“[W]e give substantial deference to the court’s weighing of evidence and balancing of the various equitable factors.”).

Affirmed

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.