Dixon Ventures Inc v. Department of Health and Human Services, 4:20-cv-01518

Dixon Ventures, an Arkansas property manager/owner managing over 300 units, sued CDC and HHS challenging the federal eviction moratorium and moved for a TRO/preliminary injunction after a March 28, 2021 extension of the CDC Order.
The CDC "Temporary Halt in Residential Evictions" was first issued Sept. 4, 2020 and extended multiple times (latest extension to June 30, 2021); Dixon filed its complaint Dec. 30, 2020 and the TRO/PI motion Mar. 30, 2021.
Dixon alleges seven tenants submitted CDC declaration forms, $43,878 in collective unpaid rent, lost management fees (~$4,380) and four lost listings (~$4,500 fees), and contends the moratorium prevents evictions and worsens financial harm.
Defendants opposed the TRO/PI, arguing Dixon lacks standing and cannot show irreparable harm; the court held a hearing Apr. 12, 2021.
The district court found Dixon has Article III standing at this stage but denied emergency injunctive relief because Dixon failed to show irreparable harm—monetary losses were compensable and speculative harm did not threaten the company’s existence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to sue	Dixon: economic losses from moratorium (unpaid rent, lost fees) give concrete injury	Defendants: insufficient traceable, concrete injury	Court: Dixon has standing at this stage (alleged lost revenue suffices)
Irreparable harm — delay & imminence	Dixon: harm increases with each month; extension triggered motion	Defendants: seven-month delay undermines urgency	Court: did not base denial on delay alone but found no irreparable harm shown
Irreparable harm — monetary loss vs. irreparable injury	Dixon: rent losses, lost listings, credit/financing harms, and inability to collect from judgment‑proof tenants	Defendants: monetary losses are compensable; federal rental assistance exists	Court: monetary loss alone is insufficient; no showing losses threaten business or are unrecoverable; TRO/PI denied

In re Rutledge, 956 F.3d 1018 (8th Cir. 2020) (context of COVID‑19 public‑health emergency)
Dep’t of Commerce v. New York, 139 S. Ct. 2551 (2019) (standing and Article III requirements)
Davis v. Federal Election Comm’n, 554 U.S. 724 (2008) (standing standard)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (injury‑in‑fact requirements)
Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109 (8th Cir. 1981) (preliminary injunction factors)
Kroupa v. Nielsen, 731 F.3d 813 (8th Cir. 2013) (application of Dataphase factors)
Iowa Utilities Bd. v. F.C.C., 109 F.3d 418 (8th Cir. 1996) (irreparable harm must be certain and imminent)
Packard Elevator v. I.C.C., 782 F.2d 112 (8th Cir. 1986) (economic loss generally not irreparable absent threat to business existence)
Sampson v. Murray, 415 U.S. 61 (1974) (availability of adequate legal remedies weighs against injunction)
Czyzewski v. Jevic Holding Corp., 137 S. Ct. 973 (2017) (monetary loss can be an Article III injury)
Watkins Inc. v. Lewis, 346 F.3d 841 (8th Cir. 2003) (movant bears burden for injunction)
Gen. Motors Corp. v. Harry Brown's, LLC, 563 F.3d 312 (8th Cir. 2009) (speculative business harms insufficient for injunction)