Barton Solar, LLC v. RBI Solar, Inc.

United States District Court for the District of Vermont · February 21, 2025 · No. 5:21-cv-00025

Summary

This order from the United States District Court for the District of Vermont denies Plaintiff Barton Solar’s motion for a mandatory injunction compelling Defendant RBI Solar to perform emergency repairs on a solar array. The court determined that the alleged damages, including repair costs and lost revenue, were quantifiable financial losses that could be adequately compensated through monetary damages at trial. Because Plaintiff failed to make the strong showing of irreparable harm required for a mandatory injunction, the court denied the motion without reaching the merits of the underlying claims.

Court
United States District Court for the District of Vermont
Writing for the Court
Mary Kay Lanthier
Jurisdiction
United States District Court for the District of Vermont
Decision date
February 21, 2025
Docket number
5:21-cv-00025
Procedural posture
Motion for mandatory injunction denied
Precedential value
nonprecedential
Disposition
other

Topics

injunctionscivil procedureremedies

Practice areas

civil procedureremediescontractscommercial litigation

Questions Presented

  1. Whether the plaintiff demonstrated a strong showing of irreparable harm sufficient for a mandatory injunction
  2. Whether the plaintiff satisfied the heightened likelihood‑of‑success standard for a mandatory injunction

Holdings

  1. The court denied the plaintiff's request for a mandatory injunction because the plaintiff failed to establish a strong showing of irreparable harm.

Key quotations

A preliminary injunction is an extraordinary remedy never awarded as of right. (at 1)

Factual background

Barton Solar, LLC owns a solar generation facility in Barton, Vermont. In 2014 Barton contracted with Ohio‑based RBI Solar to design and install a racking system. After installation, frost heave caused upward movement of embedded posts, damaging the array. Barton alleges RBI’s design failed to account for frost heave and seeks emergency repairs or certification that the array is structurally sound.

Procedural history

Plaintiff filed a motion for a mandatory injunction to compel emergency repairs to the solar array. Defendant opposed. The motion and a related partial summary judgment motion were stayed pending settlement. After settlement talks failed, the court held a hearing on Jan. 6, 2025, and issued this order denying the injunction.

Court Document

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