Lawrence Little v. Ije Ekweani, et al.

Little v. Ekweani, Civil No. 1:26-cv-00863-JRR (D. Md. May 1, 2026) · United States District Court for the District of Maryland · May 1, 2026 · No. 1:26-cv-00863-JRR

Summary

The United States District Court for the District of Maryland denied Lawrence Little’s emergency motion for a temporary restraining order and preliminary injunction seeking emergency housing assistance. The court held that Plaintiff had not complied with Federal Rule of Civil Procedure 65’s notice and certification requirements and had not shown imminent irreparable harm, in part because the alleged homelessness had persisted for approximately three years.

Holdings

  1. The motion for a temporary restraining order or preliminary injunction was properly denied because Plaintiff had not served Defendants and had not provided a written certification detailing his efforts to provide notice or why notice should not be required.
  2. Plaintiff failed to demonstrate the immediate and irreparable harm necessary to support a TRO or preliminary injunction.

Questions Presented

  1. Whether Plaintiff could obtain a temporary restraining order or preliminary injunction without serving Defendants or providing the written certification required by Federal Rule of Civil Procedure 65.
  2. Whether Plaintiff clearly demonstrated immediate and irreparable harm sufficient to support preliminary injunctive relief.

Disposition

other

Cases Cited (9)

  • Maages Auditorium v. Prince George’s Cnty., 4 F. Supp. 3d 752, 760 n.1 (D. Md. 2014), aff’d, 681 F. App’x 256 (4th Cir. 2017)(followed)
  • Frazier v. Prince George’s Cnty., 86 F.4th 537, 543 (4th Cir. 2023)(followed)
  • Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20, 22 (2008)(followed)
  • Sci. Sys. & Applications, Inc. v. United States, PWG-14-2212, 2014 WL 3672908, at *3 (D. Md. July 22, 2014)(followed)
  • Lee v. Meyers, ELH-21-1589, 2021 WL 4804018, at *3 (D. Md. Oct. 14, 2021)(followed)
  • Candle Factory, Inc. v. Trade Assocs. Grp., Ltd., 23 F. App’x 134, 137–38 (4th Cir. 2001)(followed)
  • Quince Orchard Valley Citizens Ass’n, Inc. v. Model, 872 F.2d 75, 80 (4th Cir. 1989)(followed)
  • Mountain Valley Pipeline, LLC v. 6.56 Acres of Land, Owned by Sandra Townes Powell, 915 F.3d 197, 216 (4th Cir. 2019)(followed)
  • Direx Israel, Ltd. v. Breakthrough Med. Corp., 952 F.2d 802, 812 (4th Cir. 1991)(followed)

Cited In (0)

No citing cases on record yet.

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