Summary
This United States District Court order denies an inmate plaintiff's renewed motion for a preliminary injunction and temporary restraining order seeking an exemption from a prison grooming policy to grow a three-inch beard. The court applies the heightened burden for mandatory or affirmative injunctions, concluding that the plaintiff failed to demonstrate irreparable injury or comply with applicable local rules. Accordingly, the motion is denied without prejudice.
Topics
Practice areas
Questions Presented
- Whether the plaintiff satisfied the heightened burden required for a mandatory preliminary injunction to grow a fist‑length beard under the First Amendment and RLIUPA.
Holdings
- The motion is denied because the plaintiff failed to meet the heightened burden for a mandatory injunction and did not comply with the local rules for a preliminary injunction or TRO.
Key quotations
““The purpose of . . . a preliminary injunction is ‘merely to preserve the relative positions of the parties until a trial on the merits can be held.’"” (695 F.2d at 539‑40)
““When a preliminary injunction is sought to force another party to act, rather than simply maintain the status quo, it becomes a ‘mandatory or affirmative injunction’ and the burden on the moving party increases.”” (275 F.3d at 1034‑35)
Factual background
The plaintiff is an inmate in the Florida Department of Corrections who is subject to a grooming policy that limits beard length. He has been allowed to maintain a two‑inch beard for nearly two years and now seeks a court order permitting a fist‑length (three‑inch) beard.
Procedural history
Plaintiff, an inmate, filed an amended complaint challenging the Florida Department of Corrections grooming policy under the First Amendment and RLIUPA. He previously sought a temporary restraining order and a preliminary injunction. The court denied the earlier motion and again denied the renewed motion on June 17, 2025.