Guille v. Eldridge

CourtDistrict Court, W.D. Virginia
DecidedSeptember 26, 2025
Docket7:24-cv-00786
StatusUnknown

This text of Guille v. Eldridge (Guille v. Eldridge) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guille v. Eldridge, (W.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT U.SC. DLEISRTKR'SI COTF FCIOCUERT FOR THE WESTERN DISTRICT OF VIRGINIA AT ROANOKE, VA FILED ROANOKE DIVISION September 26, 2025 LAURA A. AUSTIN, CLERK BY: s/ M.Poff, Deputy Clerk Adrian Guille, ) ) Plaintiff, ) ) v. ) Civil Action No. 7:24-cv-00786 ) Officer J. Eldridge et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Plaintiff Adrian Guille, a Virginia inmate proceeding pro se, filed this action pursuant to 42 U.S.C. § 1983, complaining about numerous conditions of confinement at Red Onion State Prison (“ROSP”). This matter is before the court on Guille’s motion for a preliminary injunction. (Dkt. 3.) For the reasons that follow, the court will deny Guille’s motion. I. Background On November 12, 2024, Guille filed a motion for a temporary restraining order and preliminary injunction in which he asked for relief related to five particular conditions at ROSP. (Id.) Because of the severity of the conditions alleged by Guille, the court directed that Defendants respond to the motion prior to formal service of the case (Dkt. 7), which they did on December 17, 2024. (Dkt. 10.) In its response, Defendants denied the conditions claimed by Guille and opposed the motion. (Id.) Guille filed a reply. (Dkt. 18.) The court then held a status conference on June 11, 2025, relating to the then-current status of the matters raised in Guille’s motion. (Dkts. 51, 58.) Based upon the contentions of the parties during the status conference, the court determined that it would hold an evidentiary hearing as to Guille’s requests for relief designated as items 2, 3, and 5 on page four of Guille’s motion for preliminary injunction. (Dkt. 59.) Specifically, the court stated that it would receive

evidence related to Guille’s allegations of (1) denial of food and weight loss, (2) insufficient law library access and the library’s failure to provide cases requested, and (3) placement into cells contaminated with urine and feces. (Id. at 1.) The evidentiary hearing was set for July 11, 2025. (Dkt. 61.) On that day, the hearing began, but Guille stated that he had mailed to the court evidence and requests for witnesses that the court had not received. (Dkt. 71.) Accordingly, the court did not proceed with the

hearing to permit additional time for Guille’s evidence and request for witnesses to be received. (Id.) On July 24, 2025, the court received from Guille documents and an identification of the witnesses Plaintiff requested, which were dated July 13, 2025. (Dkt. 73.) The court never received copies of the submissions supposedly sent by Guille prior to July 11, 2025. The evidentiary hearing was reset for and conducted on September 23, 2025. During the hearing, the parties presented evidence,witness testimony, and argument on the motion.

II. Standard of Review Federal Rule of Civil Procedure 65(a) authorizes courts to issue preliminary injunctions. “A preliminary injunction is an extraordinary remedy intended to protect the status quo and prevent irreparable harm during the pendency of a lawsuit.” Di Biase v. SPX Corp., 872 F.3d 224, 230 (4th Cir. 2017). The court may grant a preliminary injunction only “upon a clear showing that the plaintiff is entitled to such relief.” Winter v. Nat. Res. Def. Council, Inc., 555

U.S. 7, 22 (2008). A preliminary injunction is “never awarded as of right.” Id. at 24. “[G]ranting a preliminary injunction should be ‘the exception,’ not ‘the rule.’” Am. Fed’n of Tchrs. v. Bessent, No. 25-1282, 2025 WL 2313244, at *3 (4th Cir. Aug. 12, 2025) (quoting Munaf v. Geren, 553 U.S. 674, 690 (2008)).

A plaintiff seeking a preliminary injunction must demonstrate (1) that he is likely to succeed on the merits; (2) that he is likely to suffer irreparable harm without preliminary relief; (3) that the balance of equities tips in his favor; and (4) that an injunction is in the public interest. Winter, 555 U.S. at 20. The court must separately consider each Winter factor to grant injunctive relief. Di Biase, 872 F.3d at 230. A failure to establish one factor, however, warrants the denial of relief. Am. Fed’n of Tchrs., 2025 WL 2313244, at *3 (noting that denying

a preliminary injunction only takes the rejection of a single factor). As the Fourth Circuit recently summarized, “Plaintiffs seeking a preliminary injunction thus face an inherently uneven playing field.” Id. To satisfy the first factor, “[a] plaintiff need not establish a certainty of success, but must make a clear showing that he is likely to succeed at trial.” Di Biase, 872 F.3d at 230 (internal quotation marks omitted). To satisfy the second, “a plaintiff must demonstrate more

than just a possibility of irreparable harm.” Id. (internal quotation marks omitted). The irreparable harm alleged by movant must be “neither remote nor speculative, but actual and imminent.” Direx Israel, Ltd. v. Breakthrough Med. Corp., 952 F.2d 802, 812 (4th Cir. 1991) (quoting Tucker Anthony Realty Corp. v. Schlesinger, 888 F.2d 969, 975 (2d Cir. 1989)). The third and fourth factors “merge” where, as here, the Government is the opposing party. Miranda v. Garland, 34 F.4th 338, 365 (4th Cir. 2022) (quoting Nken v. Holder, 556 U.S. 418, 435 (2009)). The typical preliminary injunction is prohibitory and generally seeks only to maintain the status quo pending a trial on the merits. See Pashby v. Delia, 709 F.3d 307, 319 (4th Cir. 2013). By contrast, mandatory injunctive relief such as that sought by Guille here “goes well

beyond simply maintaining the status quo pendente lite, is particularly disfavored, and should not be issued unless the facts and law clearly favor the moving party.” Taylor v. Freeman, 34 F.3d 266, 270 n.2 (4th Cir. 1994) (quoting Martinez v. Mathews, 544 F.2d 1233, 1243 (5th Cir. 1976)). A mandatory injunction is warranted in only the most extraordinary circumstances. Id. at 270 (citing Wetzel v. Edwards, 635 F.2d 283, 286 (4th Cir. 1980)). Further, “[i]t is well established that absent the most extraordinary circumstances, federal courts are not to

immerse themselves in the management of state prisons or substitute their judgment for that of the trained penological authorities charged with the administration of such facilities.” Id. at 268; see also Rogers v. Scurr, 676 F.2d 1211, 1214 (8th Cir. 1982) (“[J]udicial restraint is especially called for in dealing with the complex and intractable problems of prison administration.”). III. Analysis

Based on the court’s review of Guille’s complaint, his motion for a preliminary injunction, the exhibits attached to Defendants’ brief opposing Guille’s motion, Guille’s reply, the parties’ exhibits admitted as part of the evidentiary hearing, and witness testimony at the evidentiary hearing, the court finds that injunctive relief should not be granted.

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Related

Munaf v. Geren
553 U.S. 674 (Supreme Court, 2008)
Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Frank E. Wetzel v. Ralph Edwards, Etc.
635 F.2d 283 (Fourth Circuit, 1980)
Rogers v. Scurr
676 F.2d 1211 (Eighth Circuit, 1982)
Taylor v. Freeman
34 F.3d 266 (Fourth Circuit, 1994)
Henry Pashby v. Albert Delia
709 F.3d 307 (Fourth Circuit, 2013)
Joseph Di Biase v. SPX Corporation
872 F.3d 224 (Fourth Circuit, 2017)
Tucker Anthony Realty Corp. v. Schlesinger
888 F.2d 969 (Second Circuit, 1989)

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Bluebook (online)
Guille v. Eldridge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guille-v-eldridge-vawd-2025.