Snipes v. Presbyterian Church (USA), 3:25-cv-00346

Plaintiff Steven L. Snipes alleges civil rights violations, fraudulent transfer, and a § 1981 claim based on his ancestors’ enslaved labor in constructing Denmark Presbyterian Church in 1854.
Snipes seeks to enjoin the Presbyterian Church (USA) and related entities from transferring or concealing assets tied to the church.
Plaintiff previously filed several motions for temporary restraining orders (TROs), which were denied; current motions are for preliminary injunction.
Defendants argue (among other grounds) that the Presbyterian Church (USA) is not a suable legal entity and that plaintiff lacks standing.
The Court denied the requested injunction, finding Snipes failed to show a strong likelihood of success on the merits or irreparable harm.
Case remains referred to a magistrate judge pending further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Likelihood of Success	Claims for 13th Amendment violation, fraudulent conveyance, and § 1981 for historical injustice and asset concealment	Claims are nonjusticiable political questions, lack standing, and church not a legal entity	No likelihood of success
Irreparable Harm	Immediate risk of asset/record concealment absent injunction	No evidence of imminent risk; already under duty to preserve records	No irreparable harm
Sufficiency of Evidence	Allegations based on own pleadings	Plaintiff fails to present evidence beyond allegations	Allegations insufficient
Need for Injunction	Necessary to preserve evidence and prevent asset transfer	No showing of imminent harm or need beyond normal discovery obligations	Relief denied

Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (sets modern preliminary injunction standard)
Bays v. City of Fairborn, 668 F.3d 814 (6th Cir. 2012) (preliminary injunction factors under Sixth Circuit law)
Overstreet v. Lexington-Fayette Urban Cnty. Gov't, 305 F.3d 566 (6th Cir. 2002) (extraordinary nature of injunctions and plaintiff's burden)