Timothy W. Wright, Jr. v. Virginia Department of Corrections, et al.

Summary

The United States District Court for the Western District of Virginia denied without prejudice Timothy W. Wright, Jr.'s motion for a preliminary injunction in his 42 U.S.C. § 1983 action against the Virginia Department of Corrections and related officials. The court held that Wright had not clearly shown a likelihood of irreparable harm under the Winter preliminary-injunction standard, particularly because he acknowledged receiving some requested accommodations. The action concerns alleged failures to provide reasonable accommodations under the Americans with Disabilities Act.

Holdings

1. A party seeking a preliminary injunction must clearly show that he is likely to succeed on the merits, likely to suffer irreparable harm without preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest; each factor must be satisfied.
2. Wright was not entitled to a preliminary injunction because his pleading did not clearly show a likelihood of irreparable harm, particularly where he acknowledged receiving some accommodations and the requested relief would not affect the status quo.

Questions Presented

1. Whether Wright was entitled to a preliminary injunction requiring prison officials to provide requested ADA accommodations and other injunctive relief.
2. Whether Wright clearly demonstrated a likelihood of irreparable harm sufficient to warrant the extraordinary remedy of a preliminary injunction.

Disposition

other