Prinell Paul v. Deputy Sheriff Sergeant Eric Johnson, et al.

Summary

The United States District Court for the Northern District of New York denied Prinell Paul's motion for a preliminary injunction in his 42 U.S.C. § 1983 action arising from his confinement at the Onondaga County Justice Center. The court held that Paul had not shown irreparable harm, a likelihood of success or sufficiently serious questions on the merits, entitlement to transfer to a facility of his choosing, or a basis for injunctive relief against nonparties or through an impermissible obey-the-law injunction.

Holdings

1. A plaintiff seeking preliminary injunctive relief must show that the threatened injury is actual and imminent, not remote or speculative, and cannot rely solely on past conduct or a generalized fear of possible future harm.
2. A movant who provides no concrete facts supporting the requested relief fails to establish either a likelihood of success on the merits or sufficiently serious questions warranting preliminary injunctive relief.
3. The court may not grant interlocutory injunctive relief over individuals who are not parties over whom it has personal jurisdiction, absent circumstances authorized by Federal Rule of Civil Procedure 65(d)(2).
4. An inmate has no constitutional right to be confined in a particular prison or correctional facility.
5. A request that defendants simply be enjoined from committing future assaults or other unlawful conduct is an impermissible or disfavored obey-the-law injunction.

Questions Presented

1. Whether Paul established irreparable harm sufficient to warrant a preliminary injunction.
2. Whether Paul demonstrated a likelihood of success on the merits, or sufficiently serious questions going to the merits with the balance of hardships tipping decidedly in his favor.
3. Whether the court could grant injunctive relief against individuals who were not parties to the action.
4. Whether Paul had a right to be transferred to and confined in a particular correctional facility.
5. Whether the requested order prohibiting future assaults and other unlawful conduct constituted an impermissible obey-the-law injunction.

Disposition

denied