Bishop Leland Lazarus v. Warden D.W. Zook, et al.

Summary

The court denies without prejudice a pro se Virginia inmate’s renewed motion for a temporary restraining order and preliminary injunction seeking a Pentecostal communal worship service on May 24, 2026. The court concludes that the requested relief concerns a specific holiday not addressed in the underlying complaint and would disrupt the status quo, making preliminary relief unavailable.

Holdings

1. A motion for a preliminary injunction must be related to the underlying complaint and is not an appropriate vehicle for asserting new claims or obtaining relief concerning a specific matter not addressed in the complaint.
2. Lazarus was not entitled to a preliminary injunction because he failed to establish the requirements for interlocutory relief, including the need for relief that would alter rather than preserve the status quo.
3. Because Lazarus was not entitled to a preliminary injunction, there was no basis to grant a temporary restraining order.

Questions Presented

1. Whether a preliminary injunction may grant relief concerning a specific religious service or holiday that was not addressed in the underlying complaint.
2. Whether Lazarus was entitled to a renewed preliminary injunction or temporary restraining order requiring defendants to provide a Pentecostal communal worship service on May 24, 2026.

Disposition

other