REDDING v. FANNING, 5:14-cv-00407

Plaintiff Vivian Redding sued the Acting Secretary of the Air Force under Title VII alleging racial discrimination by a supervisor who favored younger white employees.
Redding seeks both monetary relief ($3,500 in the motion; $50,000 in the amended complaint) and a 15-day period of comp time as injunctive relief to "re-energize" himself.
Redding filed a motion for temporary/injunctive relief; the court treated it as a request for a preliminary (mandatory) injunction to compel affirmative relief (comp time).
The court evaluated the motion under the standard for preliminary injunctions (four-factor test) and noted an elevated burden for mandatory injunctions.
The court found Redding failed to show irreparable harm because his requested relief is monetary or otherwise compensable by money.
The court denied the motion for injunctive relief and noted that a motion is not the proper method to request in forma pauperis status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a preliminary (mandatory) injunction should be issued to award 15 days comp time and monetary relief	Redding requested comp time (15 days) and monetary awards to remedy alleged discrimination and "re-energize" him	Implicitly: the relief is not warranted; any monetary harm can be remedied by money and mandatory injunctions require clear showing	Denied — Redding failed to show irreparable harm; requested relief is compensable by money, so injunction inappropriate
Whether movant demonstrated irreparable injury necessary for preliminary injunction	Redding asserted injury from discrimination and need for comp time and money	Court: injury appears monetary/compensable; not actual and imminent irreparable harm	Held against Redding — no irreparable harm shown
Applicable standard/burden for mandatory preliminary injunction	Redding sought affirmative relief (comp time), triggering a higher burden	Court applied elevated standard and four-factor test for injunctions	Court declined to grant such a mandatory injunction absent rare, clearly favorable facts/law
Proper procedure to request in forma pauperis status	Redding may be pro se and could seek IFP	Court noted a separate IFP application was forwarded; a motion for injunctive relief is not the proper vehicle	Procedural note — IFP must be sought via § 1915(a) application rather than injunctive-motion

Klay v. United Healthgroup, Inc., 376 F.3d 1092 (11th Cir. 2004) (describing preliminary injunction as preserving the status quo to prevent irreparable injury)
Siegel v. LePore, 234 F.3d 1163 (11th Cir. 2000) (irreparable injury must be actual and imminent)
Campos v. I.N.S., 70 F. Supp. 2d 1296 (S.D. Fla. 1998) (preserving ability to render meaningful decision justifies preliminary injunction)
Keeton v. Anderson-Wiley, 664 F.3d 865 (11th Cir. 2011) (sets out four-factor preliminary injunction test)
Caron Found. of Fla., Inc. v. City of Delray Beach, 879 F. Supp. 2d 1353 (S.D. Fla. 2012) (mandatory injunctions should be granted only in rare instances with clear facts and law)
Miami Beach Fed. Sav. & Loan Ass’n v. Callender, 256 F.2d 410 (5th Cir. 1958) (quoted authority on rare-use standard for mandatory injunctions)
Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (adopting as binding pre-1981 Fifth Circuit decisions)