BROWN v. MAYO CORRECTIONAL INSTITUTION
1:13-cv-00145
N.D. Fla.Jun 4, 2014Background
- Plaintiff Brown seeks a TRO and/or preliminary injunction and transfer from Mayo C.I. due to safety concerns and access to legal matters.
- Court directed Brown to amend his complaint to relate to clearly connected claims; amended complaint due July 7, 2014.
- TRO standard: improper for Brown as he failed to certify notice efforts and to identify jurisdictional parties.
- Preliminary injunction standard: four-factor test; plaintiff bears burden for all factors; Brown’s allegations are generalized and lack irreparable injury.
- Court notes transfer requests are non-justiciable as prisoners have no constitutional right to pick a facility; safety claims do not warrant court-ordered housing changes.
- Conclusion: motion for TRO/injunction and related safety filing denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brown is entitled to a TRO. | Brown contends imminent harm warrants relief. | Brown failed to show immediate irreparable injury and proper notice; no jurisdictional clarity. | Denied; procedural defects and lack of irreparable injury. |
| Whether Brown is entitled to a preliminary injunction. | Brown seeks protection from retaliation and safety concerns. | No substantial likelihood of success, no irreparable injury, and no balance of harms favoring Brown. | Denied; four-factor test not satisfied. |
| Whether the Court may transfer Brown to another facility. | Court should order transfer for safety. | No constitutional right to transfer; housing decisions rest with corrections authorities. | Denied; court lacks authority to compel transfer. |
Key Cases Cited
- Carillon Importers, Ltd. v. Frank Pesce Intern. Group Ltd., 112 F.3d 1125 (11th Cir. 1997) (guides discretion for preliminary injunction standards)
- United States v. Jefferson County, 720 F.2d 1511 (11th Cir. 1983) (four-factor injunction standard; burden on movant)
- Siegel v. LePore, 234 F.3d 1163 (11th Cir. 2000) (four-factor test for preliminary injunctions)
- Meachum v. Fano, 427 U.S. 215 (1976) (no protected right to institutional transfer; prison assignment discretion)
- Beltran v. Smith, 458 U.S. 1303 (1982) (Attorney General discretion over prison transfers; no automatic relief)