Clinton Lee Powers v. Secretary, Florida Department of Corrections, 691 F. App'x 581

Plaintiff Clinton Lee Powers, a Florida prisoner and self-identified Messianic Jew, sought a preliminary injunction under RLUIPA to require prison officials to provide pre-prepared meals for Shabbat.
Powers asserted his faith forbids preparing food or eating food prepared by others on Shabbat, so he requested advance-provided meals to avoid violating his religious practice.
The district court denied Powers’ second motion for a preliminary injunction, concluding he failed to satisfy the four-part injunction test (likelihood of success, irreparable harm, balance of harms, public interest).
The district court noted Powers had been a practicing Messianic Jew since at least 2012 but did not seek relief about Saturday meals until December 2015, and found this unexplained delay undermined his claim of imminent irreparable harm.
Powers argued on appeal that his religious understanding had been evolving and the district court should not dissect his beliefs; the court observed he did not present that explanation in his verified filings below.
The Eleventh Circuit affirmed, holding the district court did not clearly abuse its discretion in denying mandatory injunctive relief, emphasizing the heavy burden on movants and that delay militates against a finding of irreparable harm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Powers showed a substantial likelihood of success on RLUIPA claim to justify a preliminary injunction	Powers: refusal to provide pre-prepared Shabbat meals substantially burdens his religious exercise	Prison: standard preliminarily not met and other requirements lacking	Court: Movant did not meet the four-prong preliminary injunction burden; no clear abuse of discretion in denying relief
Whether Powers demonstrated imminent irreparable harm	Powers: failing to get pre-prepared meals would force him to violate his faith now	Prison: unexplained delay in seeking relief undermines claim of imminent harm	Court: Delay (seeking relief in 2015 despite practicing since 2012) undercuts irreparable-harm showing; denial affirmed
Whether mandatory injunctive relief was appropriate (vs. maintaining status quo)	Powers: requested mandatory relief to change meal provision	Prison: mandatory relief is disfavored and requires clear facts and law favoring movant	Court: Mandatory relief is extraordinary and disfavored; facts did not clearly favor Powers
Whether the court may probe sincerity/evolution of religious beliefs	Powers: court should not dissect or question his faith or evolving beliefs	Prison: lack of evidence in filings of evolving beliefs supports relying on delay	Court: Courts must not question sincerity, but Powers failed to present evolving-belief evidence below; district court did not clearly abuse discretion

Mitsubishi Int’l Corp. v. Cardinal Textile Sales, Inc., 14 F.3d 1507 (11th Cir. 1994) (standard of review for preliminary injunctions and limited review)
Siegel v. LePore, 234 F.3d 1163 (11th Cir. 2000) (preliminary injunction reversal standard; clear abuse of discretion)
Four Seasons Hotels And Resorts, B.V. v. Consorcio Barr, S.A., 320 F.3d 1205 (11th Cir. 2003) (four-factor preliminary injunction test)
Ne. Florida Chapter of Ass’n of Gen. Contractors of Am. v. City of Jacksonville, Fla., 896 F.2d 1283 (11th Cir. 1990) (preliminary injunction preserves status quo)
Martinez v. Mathews, 544 F.2d 1233 (5th Cir. 1976) (mandatory preliminary relief is particularly disfavored)
Watts v. Florida Int’l Univ., 495 F.3d 1289 (11th Cir. 2007) (courts should not question validity of a litigant’s religious beliefs)
Wreal, LLC v. Amazon.com, Inc., 840 F.3d 1244 (11th Cir. 2016) (delay in seeking preliminary injunction weighs against finding irreparable harm)