Simpson v. Orlando Health South Lake Hospital, 6:25-cv-01129

Civica Simpson, proceeding pro se, brought a civil rights action under 42 U.S.C. § 1983 against Orlando Health South Lake Hospital, Steven S. Bocas, and unnamed defendants.
Simpson was the long-term custodial caregiver for a 38-year-old individual and sought to prevent the hospital and others from taking steps regarding the patient's remains without authorization.
Days prior, Simpson filed a first emergency motion to prevent modification or termination of the patient's life support, which was denied for lack of likelihood of success on the merits.
Simpson then filed a second emergency motion seeking a temporary restraining order and preliminary injunction to enjoin unauthorized handling of the patient's remains.
The court determined a response from defendants was unnecessary and reviewed the motion based on prior findings and the legal standard for injunctive relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to TRO/Preliminary Injunction	Needs injunction to control disposition of remains	Not required (not appeared)	Plaintiff failed to show likelihood of success on § 1983 claim
Likelihood of Success on Merits (§ 1983 claim)	Claims hospital's actions violate civil rights	N/A	Plaintiff cannot show action under color of law
Color of Law requirement for § 1983	Implies hospital's actions qualify	N/A	Court finds color of law element not met
Injunctive Relief Standard	All elements met, merits require relief	N/A	Plaintiff did not meet burden under mandatory factors

Siegel v. LePore, 234 F.3d 1163 (11th Cir. 2000) (extraordinary relief not to be granted unless movant clearly establishes all prerequisites for injunction)
Johnson & Johnson Vision Care, Inc. v. 1-800 Contacts, Inc., 299 F.3d 1242 (11th Cir. 2002) (outlining factors to be met for preliminary injunction relief)
Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1223 (11th Cir. 2005) (first requirement of likelihood of success on the merits is most important for injunctions)