Muntaqim v. Hobbs, 514 S.W.3d 464

Malik Muntaqim, an ADC inmate and member of the Nation of Islam (NOI), alleged ADC deprived him of NOI religious literature (notably The Final Call) and barred him from leading NOI services.
He filed a pro se suit against 22 ADC employees, attaching multiple ADC-level grievances from Ouachita, Cummins, and Varner units.
Muntaqim moved for a preliminary injunction, summary judgment, and default judgment seeking relief for alleged First Amendment, Fourteenth Amendment, and RLUIPA violations.
The Jefferson County Circuit Court denied the motions without an evidentiary hearing, concluding Muntaqim had not shown likely success on the merits or that the status quo should be altered.
Muntaqim appealed; the Arkansas Supreme Court held the denial of summary judgment was not appealable but found the circuit court abused its discretion by denying the preliminary-injunction motion without a hearing and remanded for a hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of summary judgment is appealable	Muntaqim sought immediate review of denial	Defendants argued order was nonfinal	Denied — interlocutory; not appealable under Arkansas rules
Whether court abused discretion by denying preliminary injunction without hearing	Muntaqim alleged denial of religious texts and prohibition on leading services caused irreparable harm and involved disputed facts	Defendants relied on record documents and argued no hearing required and no likelihood of success shown	Reversed in part — court abused discretion; remanded for an evidentiary hearing on the preliminary injunction

AJ & K Operating Co. v. Smith, 355 Ark. 510, 140 S.W.3d 475 (Ark. 2004) (standard of review for preliminary injunction; abuse of discretion)
Jones v. Double "D" Props., Inc., 352 Ark. 39, 98 S.W.3d 405 (Ark. 2003) (definition of abuse of discretion)
Drummond Citizens Ins. Co. v. Sergeant, 266 Ark. 611, 588 S.W.2d 419 (Ark. 1979) (injunctions are extraordinary relief)
Custom Microsystems, Inc. v. Blake, 344 Ark. 536, 42 S.W.3d 453 (Ark. 2001) (burden to show reasonable probability of success on merits for injunction)
Doe v. Ark. Dep't of Human Servs., 357 Ark. 413, 182 S.W.3d 107 (Ark. 2004) (appellate limits when reviewing injunction rulings)
All Care Nursing Serv., Inc. v. Bethesda Mem'l Hosp., Inc., 887 F.2d 1535 (11th Cir. 1989) (trial court need not always hold an evidentiary hearing on preliminary injunctions)
Fort Smith Symphony Orchestra, Inc. v. Fort Smith Symphony Ass'n, Inc., 285 Ark. 284, 686 S.W.2d 418 (Ark. 1985) (preliminary injunctions may issue without a hearing where affidavits or verified complaints show irreparable harm)
Elrod v. Burns, 427 U.S. 347 (U.S. 1976) (denial of First Amendment freedoms constitutes irreparable harm)