Summary
The United States District Court for the District of Columbia granted a temporary injunction barring the Department of Justice from disclosing records from Special Counsel Robert K. Hur’s investigation to the plaintiffs. The court found that the complex legal issues, potential irreparable harm to Joseph R. Biden Jr.’s privacy and reputation, lack of immediate need for disclosure, and risk of mooting appellate review warranted preserving the status quo for three weeks.
Court
United States District Court for the District of Columbia
Jurisdiction
United States District Court for the District of Columbia
Decision date
June 19, 2026
Docket number
No. 24-cv-645 (DLF)
Disposition
other
Questions Presented
- Whether Federal Rule of Civil Procedure 62(d) permits a district court to issue an injunction pending appeal after denying an interlocutory motion for a preliminary injunction.
- Whether the circumstances warranted a temporary injunction barring disclosure of the Zwonitzer materials while the D.C. Circuit considered Biden's request for an injunction pending appeal.
Holdings
- Federal Rule of Civil Procedure 62(d) permits a district court to grant an injunction while an appeal is pending from an interlocutory order refusing an injunction, and the applicable standard may be more flexible than a rigid application of the traditional four-part preliminary-injunction test.
- A temporary, status-quo-preserving injunction was warranted because the merits issues were difficult and weighty, disclosure threatened irreparable privacy and reputational harm, the plaintiffs had no immediate need for the records, and disclosure could moot the appeal.
Court Document
Open PDFLoading document…