Moses 231885 v. Finco, 1:16-cv-00248

Plaintiffs are incarcerated individuals who allege they are being denied appropriate religious meals and seek a preliminary injunction ordering prison officials to provide meals of their choosing.
Plaintiffs filed a motion for a preliminary injunction (ECF No. 31) in the U.S. District Court for the Western District of Michigan.
The magistrate judge reviewed the governing standard for preliminary injunctions and the four-factor balancing test applied in the Sixth Circuit.
The court found Plaintiffs did not show they were likely to prevail on the merits or that legal remedies were inadequate to address any injury alleged.
The court concluded that public interest does not favor judicial intervention in prison management absent evidence justifying such interference.
The magistrate judge recommended denial of the preliminary injunction and advised parties of the 14-day objection period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiffs are entitled to a preliminary injunction ordering specific religious meals	Plaintiffs contend denial of religious meals violates their rights and causes irreparable harm requiring immediate relief	Defendants argue prison management decisions and available remedies negate need for injunctive relief	Denied — Plaintiffs failed to show likelihood of success or inadequate legal remedies
Whether Plaintiffs demonstrated irreparable injury absent injunction	Plaintiffs assert injury from denial of religious accommodations that cannot be remedied later	Defendants assert available administrative or legal remedies suffice and no immediate irreparable harm shown	Denied — irreparable injury not established
Whether injunction would harm others or affect public interest	Plaintiffs argue public interest favors protecting religious exercise	Defendants argue judicial interference in prison operations harms institutional management and public interest	Court held public interest does not support intervention without justification
Standard and burden for preliminary injunction in prison context	Plaintiffs rely on the injunction standard to obtain relief for alleged constitutional violations	Defendants rely on deferential treatment of prison administration and requirement to balance factors	Court applied Sixth Circuit balancing test and exercised discretion to deny injunctive relief

Overstreet v. Lexington-Fayette Urban County Gov’t, 305 F.3d 566 (6th Cir. 2002) (describing preliminary injunction as an extraordinary remedy)
Dana Corp. v. Celotex Asbestos Settlement Trust, 251 F.3d 1107 (6th Cir. 2001) (party must show no adequate legal remedy before injunctive relief)
Samuel v. Herrick Memorial Hospital, 201 F.3d 830 (6th Cir. 2000) (sets out four-factor injunction test in Sixth Circuit)
Six Clinics Holding Corp., II v. Cafcomp Systems, Inc., 119 F.3d 393 (6th Cir. 1997) (factors are competing considerations to be balanced)
Michigan Bell Telephone Co. v. MFS Intelenet of Michigan, Inc., 16 F. Supp. 2d 828 (W.D. Mich. 1998) (discussing injunction factor balancing)
Thomas v. Arn, 474 U.S. 140 (1985) (procedural rule on waiver for failure to timely object to magistrate recommendations)
United States v. Walters, 638 F.2d 947 (6th Cir. 1981) (same)