Kings Plaza Dental, P.C. v. Dentaquest IPA of New York, LLC
1:25-cv-02421
| S.D.N.Y. | Mar 26, 2025Background
- Multiple dental practices (Plaintiffs) contracted with DentaQuest IPA of New York, LLC for dental provider services through various agreements amended over the years.
- In January 2025, DentaQuest issued notices of non-renewal or termination to Plaintiffs, effective March 31 or April 1, 2025.
- Plaintiffs sought an emergency temporary restraining order (TRO) and preliminary injunction to prevent termination and maintain the status quo, asserting immediate risk of closure for practices serving predominantly Medicaid patients.
- The court previously denied an ex parte TRO due to lack of evidence for irreparable harm and failure to notify Defendant.
- Defendant opposed Plaintiffs' expedited schedule, arguing Plaintiffs manufactured the emergency as contract changes had been discussed since July 2024.
- The present order grants a temporary restraining order to preserve the status quo until a hearing can be held, and sets a briefing and hearing schedule.
Issues
| Issue | Plaintiffs' Argument | Defendant's Argument | Held |
|---|---|---|---|
| TRO to prevent contract terminations | Practices face imminent closure and irreparable harm if terminated | No true emergency; Plaintiffs were aware since July 2024; expedited process is unfair | TRO granted, status quo maintained pending hearing |
| Expedited briefing/hearing schedule | Immediate schedule needed to prevent closures | Schedule is unreasonable and prejudicial; process should be slower | Court adopts its own reasonable schedule |
| Ex parte application propriety | Prior notice was given to Defendant’s counsel | Plaintiffs failed to show facts in original application | Plaintiffs must now serve Defendant, or TRO will be vacated |
| Status quo pending preliminary injunction | Preliminary relief needed to keep practices open | Situation ongoing; no urgency | Status quo order issued until April 8, 2025 hearing |
Key Cases Cited
- AIM Int’l Trading LLC v. Valcucine SpA, 188 F. Supp. 2d 384 (S.D.N.Y. 2002) (irreparable harm standard for injunctions)
- Roso-Lino Beverage Distributors, Inc. v. Coca-Cola Bottling Co. of New York, 749 F.2d 124 (2d Cir. 1984) (irreparable harm and business closure as rationale for injunctive relief)
- Garcia v. Yonkers Sch. Dist., 561 F.3d 97 (2d Cir. 2009) (purpose of temporary restraining orders is to preserve status quo)
- Granny Goose Foods, Inc. v. Bhd. of Teamsters & Auto Truck Drivers Loc. No. 70 of Alameda Cnty., 415 U.S. 423 (1974) (limits of ex parte temporary restraining orders)
- Citibank, N.A. v. Citytrust, 756 F.2d 273 (2d Cir. 1985) (delay undercuts claim of irreparable harm)