Singh v. Carter, 185 F. Supp. 3d 11

Capt. Simratpal Singh sued the Secretary of Defense and others seeking a permanent religious accommodation to wear uncut hair, a beard, and a turban while serving in the Army; he moved for a preliminary injunction and to consolidate related Sikh-plaintiff cases.
After a TRO, Assistant Secretary of the Army Debra Wada granted a long-term accommodation (Mar. 30, 2016) allowing beard/turban/hair with specific limits tied to helmet/gas-mask safety, grooming dimensions, and duty assignments.
The accommodation is subject to quarterly command assessments on unit cohesion/morale/discipline/health/readiness, may be suspended for hazardous duties, and will be re-evaluated within one year (or sooner for military necessity).
Singh sought a preliminary injunction to remove all limitations except prescribed interim appearance standards and to make the accommodation permanent; defendants argued the case was moot because an accommodation was granted.
The Court held the claims were not moot (plaintiff did not receive an unconditional permanent accommodation) but denied the preliminary injunction because Singh failed to show likely irreparable harm and the Army’s limited monitoring/review conditions implicated legitimate military interests.
The Court denied consolidation with Singh v. McConville, finding differences in plaintiffs’ statuses (active commissioned officer vs. enlistees/trainees), factual allegations, and procedural posture counseled against consolidation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of claims after Army granted a long-term accommodation	Singh: accommodation is not permanent; seeks court-ordered permanence so claims not moot	Defs: accommodation moots injunctive request because it allows beard/turban/hair	Court: Not moot—relief sought (permanent, unconditional accommodation) not fully furnished
Entitlement to preliminary injunction making accommodation permanent	Singh: needs injunction to secure RFRA protections and prevent discriminatory treatment	Defs: no imminent irreparable harm; injunction unnecessary and intrusive into military judgment	Court: Denied—plaintiff failed to demonstrate likely irreparable harm; high standard for mandatory injunction not met
Lawfulness and effect of quarterly command assessments	Singh: assessments are intrusive, discriminatory, give commanders unbridled discretion and chill religion	Defs: assessments are reasonable, historically used, and tied to legitimate military interests	Court: Assessments troubling but plaintiff did not show they will cause imminent irreparable harm; military interests justify deference
Consolidation with related Singh v. McConville cases	Singh: consolidation would promote judicial economy and uniform resolution	Defs: plaintiffs differ in status, claims, and posture; consolidation would create confusion and delay	Court: Denied—differences in parties, allegations, and stages make consolidation inappropriate

Aamer v. Obama, 742 F.3d 1023 (D.C. Cir.) (preliminary-injunction standard articulated)
Sherley v. Sebelius, 644 F.3d 388 (D.C. Cir.) (preliminary-injunction standard)
Mazurek v. Armstrong, 520 U.S. 968 (U.S.) (extraordinary nature of injunctive relief; burden to make a clear showing)
Winter v. Nat. Res. Def. Council, 555 U.S. 7 (U.S.) (plaintiff must show likelihood of irreparable harm; cannot rely on mere possibility)
Davis v. Pension Benefit Guaranty Corp., 571 F.3d 1288 (D.C. Cir.) (discussion of sliding-scale approach and injunction factors)
In re Navy Chaplaincy, 738 F.3d 425 (D.C. Cir.) (all four preliminary-injunction factors must be met)
Dorfmann v. Boozer, 414 F.2d 1168 (D.C. Cir.) (mandatory injunctions should be sparingly exercised)
Gilligan v. Morgan, 413 U.S. 1 (U.S.) (deference to military judgments on force composition and control)
Goldman v. Weinberger, 475 U.S. 503 (U.S.) (military deference regarding uniform and appearance rules)