ChristNet Inc. v. Taylor, City of

CourtDistrict Court, E.D. Michigan
DecidedJanuary 16, 2025
Docket2:24-cv-11561
StatusUnknown

This text of ChristNet Inc. v. Taylor, City of (ChristNet Inc. v. Taylor, City of) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ChristNet Inc. v. Taylor, City of, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CHRISTNET INC., a Michigan non-profit corporation, Plaintiff, Case No. 24-11561 v. Hon. Denise Page Hood

CITY OF TAYLOR,

Defendant. _______________________________/ ORDER GRANTING PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION [ECF NO. 2] I. INTRODUCTION Before the Court is Plaintiff, ChristNet Inc.’s, Motion for Preliminary Injunction. [ECF No. 2]. On June 16, 2024, this Court granted Plaintiff’s Emergency Motion for Temporary Restraining Order (“TRO”) and required Defendant, City of Taylor, to respond pursuant to the schedule set forth in the Order. [ECF No. 4]. On June 21, the parties filed a Stipulated Order for Extension of Briefing Dates, whereby, Defendant agreed that the TRO would remain in effect until the date set for hearing or until further Order of this Court. [ECF No. 7]. The Motion for Preliminary Injunction is fully briefed and oral argument was held on July 24, 2024. See [ECF Nos. 10 and 12]. For the reasons stated herein, Plaintiff’s motion for preliminary injunction is granted. II. BACKGROUND Plaintiff is a non-profit corporation which provides services to homeless and in-need individuals in Wayne County. [ECF No. 1, PageID.1-2]. On August 9,

2022, Plaintiff received a certificate of occupancy from Defendant, approving its commercial occupancy of the property located at 25275 Eureka Road. Id. On September 24, 2023, Plaintiff received a business license from the Defendant to

operate a facility providing nonprofit employment services and related resources. Id. Plaintiff provides meals, showers and hygiene support, laundry facilities, off- site overnight housing, identification assistance, referral services, employment, and other services to its guests. Id. Some of Plaintiff’s work is accomplished through

its partnership with Wayne-Metropolitan Community Action Agency (“Wayne- Metro”). Id. at PageID.3. While Plaintiff began occupying its current building in September of 2022, it purchased the property in 2013 and has been performing

renovations since that time. Id. As the cost of final renovations increased, Plaintiff and Wayne-Metro entered into an agreement whereby Plaintiff deeded the property to Wayne-Metro, which then funded the project to completion in exchange for a lease back to Plaintiff for $1/year for ten years, renewable for an additional ten

years. Id. On April 8, 2024, Plaintiff received a notice signed by the Mayor of the City of Taylor and the City Clerk revoking its business license, effective May 13, 2024.

Id. at PageID.5. Defendant asserts that Plaintiff’s operations are a detriment to the health, safety and welfare of the residents and businesses that live and operate in the surrounding area as the basis for revocation. Id. Plaintiff appealed the decision,

and an appeal hearing was held May 21, 2024. Id. In preparation for the hearing, Plaintiff obtained documents through a Freedom of Information Act request. Id. Plaintiff alleges that the FOIA documents revealed that Defendant and Wayne-

Metro had been engaged in a campaign for over a year to orchestrate a breach of the lease for Plaintiff’s occupancy, so that Wayne-Metro could take possession of the property and conduct its own operations from the building. Id. at PageID.6. The campaign allegedly included complaints about Plaintiff’s business operations from

Wayne-Metro which were never investigated and images of blighted areas around the city being associated with Plaintiff. Id. After the appeal hearing, the City Council upheld the decision to revoke

Plaintiff’s business license and Plaintiff received a letter dated June 3, 2024, stating that its business license would officially be revoked Sunday, June 16, 2024. Id. at PageID.7. Plaintiff alleges that the Defendant denied it due process by failing to provide Plaintiff a hearing in front of the Mayor as required by City Code of

Ordinance § 10-23 before revoking its business license. [ECF No. 2, PageID.51]. Plaintiff alleges four counts: (1) Procedural Due Process Violation, (2) Writ of Mandamus (3) Substantive Due Process Violation, (4) Violation of 42 U.S.C. §

1983. [ECF No. 1]. Plaintiff seeks a preliminary injunction preventing Defendant from revoking its business license pending the outcome of this matter. [ECF No. 2].

Defendant argues that Plaintiff is not entitled to a preliminary injunction because it provided Plaintiff constitutional due process by providing “pre- revocation notice of its intent to revoke the license and an appeal hearing before

the Mayor and City Council, Plaintiff lacks standing to request a writ of mandamus, and Defendant had a rational basis for its decision to revoke Plaintiff’s business license. [ECF No. 10, PageID.109]. Defendant further argues that “Plaintiff has little to no likelihood of success on the merits of the Complaint.

Moreover, it had an adequate remedy in the appeal it failed to pursue, and otherwise has pled claims for monetary damages which defeats Plaintiff’s claim of an irreparable harm that would need to be remedied through injunctive relief.” Id.

at PageID.109-10. III. ANALYSIS “Issuance of a preliminary injunction is an extraordinary remedy.” JGMM realty, L.L.C. v. LNR Partners, L.L.C., No. 16-10633, 2016 WL 1719925, *1 (E.D.

Mich. April 28, 2016). “A plaintiff seeking a preliminary injunction must establish (1) that [s]he has a strong likelihood to succeed on the merits; (2) that [s]he is likely to suffer irreparable harm without the injunction; (3) that the injunction

would not cause substantial harm to others; and (4) that an injunction is in the public interest.” Id. quoting Livonia Property Holdings v. 12840-12976 Farmington Rd. Holdings, 717 F. Supp. 2d 724, 731 (E.D. Mich. 2010). “Although

the factors are to be balanced, a finding that there is no likelihood of irreparable harm, Winter, 129 S.Ct. at 375, or no likelihood of success on the merits, Gonzales v. Nat'l Bd. of Med. Exam'rs, 225 F.3d 620, 625 (6th Cir.2000), is usually fatal.”

CLT Logistics v. River W. Brands, 777 F. Supp. 2d 1052, 1064 (E.D. Mich. 2011). A. Likelihood of Success 1. Procedural Due Process The Fourteenth Amendment protects citizens from “any law which

shall…deprive any person of life, liberty, or property, without due process of law.” U.S. Const. amend. XIV, § 1. “The United States Constitution does not create or define property rights, but it does protect property rights as defined by state law.

Big Momma's Soul Kitchen v. Louisville-Jefferson Cnty. Metro Gov't, 551 F. Supp. 2d 620, 624 (W.D. Ky. 2008). “To succeed on that claim, the plaintiffs must first show that they had a property interest protected under the Fourteenth Amendment and that they were deprived of that interest, and then show that the procedures

provided by the defendant were not sufficient to protect their rights to due process.” Id. Plaintiff argues that it was denied procedural due process because Defendant

failed to provide any hearing before the mayor, as required by City of Taylor Code of Ordinance Section 10-23 and 10-25, before it revoked Plaintiff’s business license. Section 10-23 states:

Grounds for refusal to issue, suspension and revocation of license.

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