Jet Midwest International v. F. Paul Ohadi, 953 F.3d 1041

JMG (aircraft reseller) became insolvent; Ohadi lent $11M in June 2015 and obtained security interests; Jet Midwest later loaned $6.5M in Sept. 2015 and took a purchase-money security interest (PMSI) in a Boeing 737.
JMG defaulted; Jet Midwest obtained a money judgment in Oct. 2017 and then sued in Feb. 2018 under the Missouri Uniform Fraudulent Transfer Act alleging JMG funneled assets to insiders (Ohadi and Woolley).
After the suit, JMG granted Ohadi an allegedly blanket lien; JMG’s bankruptcy stayed the fraudulent-transfer case but was dismissed and the case resumed.
PMC Aviation intervened, produced Side Letter Agreements suggesting a scheme funneling funds to Ohadi and Woolley, and argued competing interests in JMG collateral.
Ohadi and Woolley scheduled a foreclosure sale listing many items (including parts from Jet’s Aircraft); Jet Midwest and PMC sought to enjoin the sale to preserve disputed assets and priority claims.
The district court issued a TRO, held a hearing, found the record needed development, granted a preliminary injunction to preserve the status quo and expedited a bench trial, and required Jet Midwest and PMC to post a $1,000,000 bond.

Issue	Jet Midwest	Ohadi & Woolley	Held
Likelihood of success on fraudulent-transfer/priority claims	Side letters, insider status, and listing of Aircraft parts show a fair chance to void Ohadi’s liens and establish Jet’s PMSI priority	Side letters were legitimate loan inducments and Ohadi’s security interests are valid	Court: Jet showed a fair chance of success; injunction proper to preserve assets pending trial
Irreparable harm from permitting foreclosure sale	Sale would destroy traceability of parts and priority rights; monetary damages likely inadequate	Any injury is compensable by money; no irreparable harm	Court: Sale would cause irreparable harm because tracing and allocating sold parts would be difficult or impossible
Balance of harms	Delay causes minor storage/depreciation but protects critical priority rights	Postponement imposes storage/maintenance costs and delay in enforcement	Court: Harms to Jet outweigh the modest burdens on Ohadi/Woolley; balance favors injunction
Public interest and procedural complaints (evidentiary hearing / bond)	Public interest favors preventing fraud and resolving competing liens before sale	Court abused discretion by not taking additional evidence and by imposing bond	Court: No abuse; district held a hearing, parties agreed to expedite trial, and bond was appropriate

PCTV Gold, Inc. v. SpeedNet, LLC, 508 F.3d 1137 (8th Cir. 2007) (deference and abuse-of-discretion standard for preliminary injunction)
Dataphase Sys., Inc. v. CL Sys., Inc., 640 F.2d 109 (8th Cir. 1981) (four-factor test for preliminary injunction)
Roudachevski v. All-Am. Care Centers, Inc., 648 F.3d 701 (8th Cir. 2011) (importance of likelihood-of-success factor)
Planned Parenthood Minn., N.D., S.D. v. Rounds, 530 F.3d 724 (8th Cir. 2008) (standard for ‘fair chance’ of success on the merits)
Mid-Am. Real Estate Co. v. Iowa Realty Co., 406 F.3d 969 (8th Cir. 2005) (injunction inappropriate if no chance of success)
Gelco Corp. v. Coniston Partners, 811 F.2d 414 (8th Cir. 1987) (monetary damages sufficient generally preclude irreparable-harm finding)
McGirr v. Rehme, 891 F.3d 603 (6th Cir. 2018) (concealment of assets can make monetary relief inadequate)
First Nat’l Bank of Steeleville, N.A. v. Erb Equip. Co., 921 S.W.2d 57 (Mo. Ct. App. 1996) (PMSI priority exception to general priority rules)