Emanuel v. Kirkland

District Court, D. Nevada·Decided January 5, 2024·No. 3:21-cv-00308·Unknown

Opinion

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TROY EMANUEL, JR., Case No. 3:21-CV-00308-CLB

Plaintiff, ORDER DENYING PLAINITFF’S MOTIONS FOR TEMPORARY v. RESTRAINING ORDER AND PRELIMINARY INJUNCTION D. KIRKLAND, et al., [ECF Nos. 29, 30] Defendants.

This case involves a civil rights action filed by Plaintiff Troy Emanuel, Jr. (“Emanuel”) against Defendant asserting an excessive force claim in violation of Emanuel’s Eighth Amendment rights. (ECF Nos. 6, 7.) Currently pending before the Court are Emanuel’s motions for temporary restraining order preliminary injunction. (ECF Nos. 29, 30.)1 For the reasons stated below, Emanuel’s motions for temporary restraining order and preliminary injunction, (ECF Nos. 29, 30), are denied. Emanuel is an inmate in the custody of the Nevada Department of Corrections (“NDOC”) and is currently housed at Ely State Prison (“ESP”) in Ely, Nevada. (ECF No. 1-1.) On July 21, 2021, Emanuel submitted his initial complaint and an application to proceed in forma pauperis. (ECF Nos. 1, 1-1.) In the complaint, Emanuel alleged the following: On January 4, 2021, Defendant Kirkland came to Plaintiff’s door to serve him food. (ECF No. 1-1 at 4.) When Kirkland opened the food slot, Plaintiff put one hand on top of his food tray and asked Kirkland why he had not fed a black inmate with a red box on his door. (Id.) Kirkland responded by slamming Plaintiff’s arm in the food slot four or five times and then putting his body weight on the food slot to smash Plaintiff’s arm even more. (Id.) Kirkland said he was tired of Plaintiff and that if Plaintiff did not close the food

1 These motions are identical documents that were improperly docketed twice. (ECF slot, he would break Plaintiff’s arm. (Id.) Plaintiff told Kirkland that he had violated Plaintiff’s rights by using excessive force. (Id.) Kirkland admitted that he was in the wrong and gave Plaintiff a food tray. (Id.) However, Kirkland then wrote a false charge against Plaintiff. (Id.) The false charges were ultimately dismissed because the video proved that Plaintiff had not done anything wrong. (Id.) Defendants Ruebart, Gittere, and Drummond did not do anything to correct Kirkland after the incident. (Id. at 5.) Pursuant to 28 U.S.C. § 1915A(a), the District Court screened the complaint on December 27, 2022. (ECF No. 5.) Based on the allegations in the complaint, the Court determined Emanuel could proceed on an Eighth Amendment excessive force claim against Defendant Kirkland. (Id. at 7.) II. EMANUEL’S MOTIONS FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION On December 29, 2023, Emanuel filed the instant motions for temporary restraining order and preliminary injunction. (ECF Nos. 29, 30.) The motions allege that after Emanuel filed this and other lawsuits against various wardens and Defendant, Defendant and others have retaliated against him in several ways. (Id.) As such, Emanuel requests that the Court order “Kirkland and his CERT team friends away from him, and to please transfer him to another prison.” (Id. at 3.) He also requests that the Court enter an order to not allow “these people to lie to [the Court]” and to prevent them from retaliating against him. (Id.) III. LEGAL STANDARD The purpose of a preliminary injunction or temporary restraining order is to preserve the status quo if the balance of equities so heavily favors the moving party that justice requires the court to intervene to secure the positions until the merits of the action are ultimately determined. University of Texas v. Camenisch, 451 U.S. 390, 395 (1981). A preliminary injunction is an “extraordinary and drastic remedy” that is “never awarded as of right.” Munaf v. Geren, 553 U.S. 674, 689-90 (2008) (citations omitted). Instead, in every case, the court “must balance the competing claims of injury and must consider the effect on each party of the granting or withholding of the requested relief.” Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (quotation marks and citation omitted). The instant motion requires the Court determine whether Plaintiff has established the following: (1) he is likely to succeed on the merits; (2) he is likely to suffer irreparable harm in the absence of preliminary relief; (3) the balance of equities tips in his favor; and (4) an injunction is in the public interest. Winter, 555 U.S. at 20 (citations omitted). An even more stringent standard is applied where mandatory, as opposed to prohibitory preliminary relief is sought. The Ninth Circuit has noted that although the same general principles inform the court’s analysis, “[w]here a party seeks mandatory preliminary relief that goes well beyond maintaining the status quo pendente lite, courts should be extremely cautious about issuing a preliminary injunction.” Martin v. International Olympic Committee, 740 F.2d 670, 675 (9th Cir. 1984); see also Committee of Cent. American Refugees v. Immigration & Naturalization Service, 795 F.2d 1434, 1442 (9th Cir. 1986). Thus, an award of mandatory preliminary relief is not to be granted unless both the facts and the law clearly favor the moving party and extreme or serious damage will result. See Garcia v. Google, Inc., 786 F.3d 733, 740 (9th Cir. 2015) (quoting Anderson v. United States, 612 F.2d 1112, 1114 (9th Cir. 1979)). Finally, the Prison Litigation Reform Act (PLRA) mandates that prisoner litigants must satisfy additional requirements when seeking preliminary injunctive relief against prison officials:

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Emanuel v. Kirkland, (D. Nev. 2024).

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