Summary
The D.C. Circuit granted the Government’s motion for a stay pending appeal of the district court’s renewed preliminary injunction in Kingdom v. Trump and dismissed the request for an administrative stay as moot. The per curiam majority concluded that the Government was likely to succeed because the district court’s order appeared to be an administrative injunction and found irreparable governmental injury. Judge Pillard dissented, concluding that the Government had not shown the imminent and substantial irreparable harm required for emergency relief.
Topics
Practice areas
Questions Presented
- Whether the Government satisfied the requirements for a stay pending appeal of the district court's renewed preliminary injunction.
- Whether the district court's renewed injunction was more properly characterized as an administrative injunction rather than a preliminary injunction or temporary restraining order.
- Whether the Government demonstrated irreparable injury sufficient to warrant emergency relief.
- Whether the request for an administrative stay was moot.
Holdings
- The Government satisfied the stringent requirements for a stay pending appeal because it showed a sufficient likelihood of success on the merits and irreparable injury.
- For purposes of the stay motion, the district court's order was best categorized as an administrative injunction rather than a preliminary injunction or temporary restraining order.
- The request for an administrative stay was dismissed as moot.
Key quotations
“appellants have satisfied the stringent requirements for a stay pending appeal.” (at 1)
“There does not appear to be any “discernible legal basis . . . for issuing administrative injunctions,” especially not in cases like this one involving the Prison Litigation Reform Act.” (at 2)
“Thus, we grant the Government’s stay request.” (at 3)
“It has failed to meet its burden to show the requisite imminent, certain, and great irreparable harm to justify a stay pending appeal of the May 26 preliminary injunction.” (at 3)
Factual background
Plaintiffs challenged the Government's new policy concerning medical care and prison administration. The district court renewed a preliminary injunction requiring the Bureau of Prisons to continue providing medical care that it had previously afforded the plaintiffs, thereby maintaining the status quo while the legality of the new policy was considered. The Government asserted that the injunction interfered with prison administration and security and exceeded the district court's equitable authority.
Procedural history
The United States District Court for the District of Columbia entered a renewed preliminary injunction on May 26, 2026, requiring the Bureau of Prisons to continue providing medical care under the existing policy while plaintiffs challenged a new policy. The Government sought an emergency stay pending appeal and an administrative stay. The D.C. Circuit granted the stay pending appeal and dismissed the request for an administrative stay as moot.