Brighter Path Alabama, LLC v. Rite of Passage, Inc.

District Court, D. Nevada·Decided March 31, 2026·No. 3:26-cv-00212·Unknown

Opinion

BRIGHTER PATH ALABAMA, LLC, Case No. 3:26-cv-00212-ART-CLB Plaintiff, ORDER ON TEMPORARY v. RESTRAINING ORDER/PRELIMINARY INJUNCTION RITE OF PASSAGE, INC., (ECF Nos. 3, 4) AND RELATED MOTIONS (ECF No. 2) Defendant.

Brighter Path Alabama, LLC (“Plaintiff”), an Alabama company that rehabilitates distressed businesses, brings this suit against Rite of Passage, Inc. (“Defendant”), a Nevada company that provides residential services for youth, for breach of contract under Nevada law. (ECF No. 1.) On March 24, 2026, it filed its Complaint and Motions for Temporary Restraining Order (“TRO”) and Preliminary Injunction. (ECF Nos. 1, 3.) It subsequently filed a Motion to Shorten Time, requesting an abbreviated briefing schedule and hearing. (ECF No. 7.) The Court granted the motion and held a hearing on March 27, 2026. (ECF No. 11.) This order follows the oral ruling announced at that hearing. I. Factual Background In 2025, Plaintiff and Defendant entered into a transaction for the purchase and sale of distressed youth treatment programs in Florida and Alabama. (ECF No. 10 at 2.) The parties entered into a separate Asset Purchase Agreement (“APA”) to manage the sale of three different residential facilities: Brighter Path Tuscaloosa (“Tuscaloosa”), Brighter Path Montgomery (“Montgomery”), and Brighter Path Courtland (“Courtland”). (ECF No. 1-1.) Relevant to the motion at issue, the APA provides for closing in two phases: the Initial Closing, which had to occur by March 6, 2026, for the Tuscaloosa facility, and the Second Closing, due to occur on March 31, 2026, addressing the Montgomery and Courtland facilities. (ECF No. 1-1.) Section 1.5 of the APA addresses contingencies upon which the Buyer (Plaintiff) and Seller (Defendant) can terminate the APA. (Id.) Failure to satisfy the conditions in Section 1.5 before the Second Closing “shall entitle Buyer to terminate” the Agreement. (Id.) Those conditions include successful issuance of Emergency Contracts, the assignment and transfer to Defendant of all Assumed Contracts “under terms and conditions reasonably acceptable” to Defendant, and the resolution of all outstanding liabilities related to those contracts. (Id.) The Assumed Contracts included an Alabama Department of Human Resources (“DHR”) Emergency Contract for operation of the Courtland facility, an Alabama DHR Emergency Contract for operation of the Montgomery facility, the Montgomery Facility Lease Agreement, and the Courtland Facility Lease Agreement. (ECF No. 1-1 at 19.) On March 13, 2026, an attorney for Plaintiff emailed Defendant’s General Counsel asking about the possibility that Defendant would not close on the Montgomery and Courtland facilities, saying that Defendant “didn’t agree in the APA to assign a newly-negotiated lease with Courtland but rather the lease in place.” (ECF No. 3-4.) Plaintiff’s counsel replied with an acknowledgment and notice of termination of the APA on the grounds that the assignment and transfer of all Assumed Contracts on terms reasonably acceptable did not occur, and that all outstanding liabilities related to the Assumed Contracts were not resolved. (ECF No. 3-5.) II. Legal Standard The standard for issuing a TRO is the same as the standard for issuing a preliminary injunction. See New Motor Vehicle Bd. of Cal. v. Orrin W. Fox Co., 434 U.S. 1345, 1347 n.2 (1977). To qualify for preliminary injunctive relief, a plaintiff must establish: (1) likelihood of success on the merits; (2) likelihood of irreparable harm; (3) that the balance of equities tips in his favor; and (4) that an injunction is in the public interest. See Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). A plaintiff seeking a mandatory, as opposed to prohibitory, injunction, “must establish that the law and facts clearly favor her position.” N.D. v. Rekydal, 102 F.4th 982, 992 (9th Cir. 2022). A mandatory injunction “orders a responsible party to take action” whereas a prohibitory injunction “simply maintain[s] the status quo.” Id. (quoting Garcia v. Google, 786 F.3d 733, 740 (9th Cir. 2015) (en banc) (internal citations omitted). “There is no good blanket answer to the question of what the status quo is,” Id. (quoting Labrador v. Poe by & through Poe, 144 S. Ct. 921, 930, 218 L. Ed. 2d 400 (2024) (Kavanaugh, J., concurring), but the Ninth Circuit has found it can be “categorized as one of action versus inaction.” Ariz. Dream Act Coal. v. Brewer, 757 F.3d 1053, 1060 (9th Cir. 2014). III. Analysis a. Likelihood of Success on the Merits The Court finds that Plaintiff has not met the heightened standard of “clear” likelihood of success on the merits for a mandatory injunction. To prove a breach of contract, a plaintiff must show: “(1) the existence of a valid contract, (2) a breach by the defendant, and (3) damage as a result of the breach.” Rivera v. Peri & Sons Farms, Inc., 735 F.3d 892, 899 (9th Cir. 2013). Further, with respect to the element of breach, a breach of a contract is “a material failure of performance of a duty arising under or imposed by agreement.” Bernard v. Rockhill Dev. Co., 103 Nev. 132, 734 P.2d 1238, 1240 (Nev. 1987). The parties dispute whether there was a breach under Section 1.5 of the APA addressing contingencies. Defendant argues that multiple contingencies required by Section 1.5 were not met: it did not have a lease with terms that were reasonably acceptable, Plaintiff did not successfully issue Emergency Contracts by the Alabama Departments, and there were outstanding liabilities related to the assumed contracts in the form of delinquent rent and incomplete maintenance. Defendant contends that Section 1.5 explicitly states that assumed contracts must be on “terms and conditions reasonably acceptable to Buyer,” and further, the landlord of the Courtland facility demanded a new lease with Defendant as opposed to an assignment of the current lease. (ECF No. 10 at 3.) In these negotiations, the landlord refused to make facility appropriate for high acuity children expected to be residents, which was known by Plaintiff prior to this lawsuit in meetings with both parties’ attorneys. (Id.) Plaintiff claims that Defendants were required to accept the Courtland Facility Lease Agreement on the same terms under which Plaintiff had the lease, and that any negotiations were an attempt to get additional landlord concessions beyond the APA’s requirements. (ECF No. 3 at 6.) The Court finds that the plain language of “terms and conditions reasonably acceptable to Buyer” encompasses the negotiations that Defendant engaged in with the landlord in order to effectuate Section 1.5. See Keife v. Metro. Life Ins. Co., 797 F. Supp. 2d 1072, 1075 (D. Nev. 2011) (“[u]nder Nevada law ... [t]he starting point for the interpretation of any contract is the plain language of the contract.”) The language is not ambiguous, because it is not susceptible to more than one interpretation. Shelton v. Shelton, 119 Nev. 492, 78 P.3d 507, 510 (2003). Therefore, Defendant properly identified a contingency that was not met, giving it the right to terminate the APA under Section 1.5. Defendant also claims that no contracts were issued by the Al

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Brighter Path Alabama, LLC v. Rite of Passage, Inc., (D. Nev. 2026).

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