Rachel Mulligan Individually and as PPA R.M. v. Devin Duprey

Summary

The Rhode Island Supreme Court affirmed a Kent County Superior Court order granting Rachel Mulligan a preliminary injunction against Devin and Kelsey Duprey. The Court concluded that the trial justice did not abuse his discretion in determining that Mulligan established the required factors for injunctive relief, including likelihood of success, irreparable harm, balance of equities, and preservation of the status quo.

Holdings

1. A decision granting a preliminary injunction is reviewed for abuse of discretion, and the appellate court's task is to determine whether the trial justice considered and resolved the four required factors without committing an abuse of discretion.
2. A party seeking a preliminary injunction must demonstrate a reasonable likelihood of success on the merits, irreparable harm absent relief, a balance of equities favoring relief, and that the injunction will preserve the status quo.
3. The Superior Court acted within its discretion in granting the preliminary injunction because its findings supported likelihood of success, irreparable harm, a favorable balance of equities, and preservation of the status quo, notwithstanding the brevity of its analysis.

Questions Presented

1. Whether the Superior Court abused its discretion by granting a preliminary injunction without adequately balancing the equities.
2. Whether the Superior Court improperly overlooked alleged fabricated allegations and failed to preserve the status quo.
3. Whether the Superior Court adequately considered the four preliminary-injunction factors.

Disposition

affirmed