Brandon Lee De Vito v. Jefferson County School District R-1; Colorado Department of Education; Colorado Office of Administrative Courts; Laura Broniak, Director and Chief Administrative Law Judge of the Colorado Office of Administrative Courts Judicial Function and in Capacity of ADA Coordinator; and Nicholas Jacob Campbell, Magistrate Judge of the District Court for Jefferson County, Colorado (Official Capacity)

Summary

The United States District Court for the District of Colorado denied Plaintiff Brandon Lee De Vito’s combined motion for a temporary restraining order and preliminary injunction. The court held that the Anti-Injunction Act barred the requested interference with ongoing state-court proceedings and that the motion did not establish grounds for injunctive relief against the school district.

Holdings

1. A plaintiff may not supplement the operative complaint's allegations through a notice contained in a motion for injunctive relief; the court therefore did not consider the post-complaint factual developments at the injunction stage.
2. The Anti-Injunction Act barred Plaintiff's request to enjoin or stay the underlying state-court proceedings because no applicable statutory exception was shown.
3. Plaintiff failed to establish a likelihood of success on the merits, and therefore failed to satisfy the required preliminary-injunction standard.
4. Plaintiff was not entitled to injunctive relief against the School District Defendant because the motion did not articulate factual or legal grounds for relief against that defendant.

Questions Presented

1. Whether Plaintiff could use a notice contained in a motion for injunctive relief to supplement the allegations of the Second Amended Complaint with post-complaint factual developments.
2. Whether the Anti-Injunction Act barred Plaintiff's request to enjoin or stay the ongoing state-court proceedings.
3. Whether Plaintiff established the likelihood-of-success element required for a temporary restraining order or preliminary injunction against the State Defendants.
4. Whether Plaintiff established a factual and legal basis for injunctive relief against the School District Defendant.

Disposition

other