Management Registry, Inc. v. A.W. Companies, Inc., 920 F.3d 1181

Management Registry (buyer) contracted to acquire a family of AllStaff staffing businesses; Allan Brown was to remain as president and Wendy Brown was to attempt to purchase one subsidiary separately.
Negotiations between Management Registry and Wendy failed; Allan and Wendy then left and formed a competing company, A.W. Companies, allegedly soliciting employees and taking client files, computers, and other proprietary materials.
Management Registry sued A.W., Allan, and Wendy in federal district court and moved for a preliminary injunction and an injunction pending appeal to restrain competition and use of proprietary materials.
The district court denied injunctive relief, finding material factual disputes and insufficient evidence of irreparable harm; Management Registry appealed the denials, which were consolidated.
On appeal, the Eighth Circuit reviewed the Dataphase four-factor preliminary-injunction test and affirmed, holding Management Registry failed to carry its burden to show irreparable harm and failed to show a likelihood of success on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Management Registry showed irreparable harm warranting a preliminary injunction	Loss of goodwill, misappropriation of files and customer relationships will cause harm that cannot be fully remedied by money	Alleged losses are quantifiable and therefore compensable by damages; factual disputes exist	Denied — plaintiff failed to show no adequate remedy at law and did not present persuasive evidence that damages were insufficient
Whether Management Registry demonstrated likelihood of success on the merits across asserted claims	Multiple contract, tort, and equitable claims arise from the Browns’ conduct and warrant injunctive relief	Plaintiff’s motion largely recited allegations without tying them to legal standards; factual disputes and insufficient focused proof	Denied — plaintiff did not make the necessary showing on the merits and did not connect facts to legal theories

Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109 (8th Cir. 1981) (sets four-factor preliminary-injunction test)
Watkins Inc. v. Lewis, 346 F.3d 841 (8th Cir. 2003) (movant bears burden for injunctive relief)
Home Instead, Inc. v. Florance, 721 F.3d 494 (8th Cir. 2013) (standard of review—abuse of discretion for injunction denials)
Gen. Motors Corp. v. Harry Brown’s, LLC, 563 F.3d 312 (8th Cir. 2009) (movant must establish threat of irreparable injury; monetary relief may be adequate)
Iowa Utils. Bd. v. FCC, 109 F.3d 418 (8th Cir. 1996) (loss of goodwill can constitute irreparable harm)
Gelco Corp. v. Coniston Partners, 811 F.2d 414 (8th Cir. 1987) (failure to show irreparable harm is sufficient to deny preliminary injunction)
Rodgers v. City of Des Moines, 435 F.3d 904 (8th Cir. 2006) (courts need not sift records to build a party’s argument)
Hilton v. Braunskill, 481 U.S. 770 (U.S. 1987) (standards pertinent to injunctions pending appeal)
Walker v. Lockhart, 678 F.2d 68 (8th Cir. 1982) (procedural points regarding injunctions pending appeal)