Climate United Fund v. Citibank, N.A.

Court of Appeals for the District of Columbia Circuit · April 16, 2025 · No. 25-5122

Summary

This per curiam order from the U.S. Court of Appeals for the D.C. Circuit addresses an emergency motion for a stay pending appeal regarding a district court's preliminary injunction against Citibank and the EPA. The appellate court partially administratively stayed the district court's order, halting requirements for fund disbursement and status reporting while preserving the status quo. The court noted that preliminary injunctions require clear justification and reserved ruling on the merits until further briefing and the district court's forthcoming opinion are received.

Court
Court of Appeals for the District of Columbia Circuit
Writing for the Court
Pillard; Katsas; Rao
Jurisdiction
United States Court of Appeals for the District of Columbia Circuit
Decision date
April 16, 2025
Docket number
25-5122
Procedural posture
Appeal from the district court's preliminary injunction order; emergency motion for stay pending appeal.
Precedential value
published
Parties
Environmental Protection Agency, Lee M. Zeldin v. Climate United Fund, Citibank, N.A.
Disposition
other

Topics

interlocutory appealappellate procedurestandard of review

Practice areas

environmental lawappellate procedureremedies

Questions Presented

  1. Whether the district court's preliminary injunction should be stayed pending appeal.
  2. Whether the injunction meets the extraordinary‑remedy standard requiring a clear showing.

Holdings

  1. The district court’s preliminary injunction is administratively stayed in part, pending further order of the court.

Key quotations

Injunctive relief is “an extraordinary remedy that may only be awarded upon a clear showing that the plaintiff is entitled to such relief.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 22 (2008).

Factual background

The dispute involves contracts, grants, awards, and funds that the plaintiffs allege are improperly withheld or managed by Citibank. The district court issued a preliminary injunction affecting the release and handling of those funds.

Procedural history

The United States District Court for the District of Columbia entered a preliminary injunction on April 15, 2025. The appellants filed an emergency motion for a stay of that injunction pending appeal. This per curiam order stays the injunction in part and requires the district court to receive a status report within 24 hours.

Remand instructions

The district court’s order is stayed insofar as it (1) enables or requires Citibank to release, disburse, transfer, otherwise move, or allow access to funds and (2) requires defendants to file a status report with the district court within 24 hours of the entry of the preliminary injunction.

Court Document

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