Martin P. Sheehan v. West Virginia Judicial Investigation Commission, et al.

CourtDistrict Court, S.D. West Virginia
DecidedApril 1, 2026
Docket2:26-cv-00180
StatusUnknown

This text of Martin P. Sheehan v. West Virginia Judicial Investigation Commission, et al. (Martin P. Sheehan v. West Virginia Judicial Investigation Commission, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Martin P. Sheehan v. West Virginia Judicial Investigation Commission, et al., (S.D.W. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

CHARLESTON DIVISION

MARTIN P. SHEEHAN,

Plaintiff,

v. CIVIL ACTION NO. 2:26-cv-00180

WEST VIRGINIA JUDICIAL INVESTIGATION COMMISSION, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

Pending before the Court is Plaintiff Martin P. Sheehan’s (“Plaintiff”) Motion for a Temporary Restraining Order and/or a Preliminary and Permanent Injunction. (ECF No. 11.) For the reasons discussed below, the Court DENIES the motion. I. BACKGROUND This action arises out of Plaintiff’s judicial candidacy for the West Virginia Supreme Court of Appeals (“WVSCA”) in the May 2026 Primary Election. (See generally ECF No. 1.) Plaintiff brings this action against the West Virginia Judicial Investigation Commission (“WVJIC”) and Teresa Tarr, Counsel for the WVJIC (collectively, “Defendants”). (See generally id.) As a judicial candidate, Plaintiff must refrain from certain conduct, as proscribed by the West Virginia Code of Judicial Conduct (“the Code”), and enforced by Defendants. (Id. at 3, ¶¶ 7, 10–11.) The Code “establishes standards for the ethical conduct of judges and judicial candidates.” (ECF No. 1 21-2 at 4, ¶ 1.) Notably, “[t]he Code consists of four Canons, numbered Rules under each Canon, and Comments that follow and explain each rule.” (Id.) Canon 4 prohibits a candidate for judicial office from engaging “In Political Or Campaign Activity That Is Inconsistent With The Independence, Integrity, Or Impartiality Of The Judiciary.” (ECF No. 21-2 at 5.) (capitalization in original).

Plaintiff takes issue with two specific provisions under Canon 4. (ECF No. 1 at 3, ¶ 12.) He argues that enforcement of Rule 4.1(A)(10) and (A)(11) “would adversely affect” his “First Amendment rights . . . in an election campaign.” (Id.) Under Rule 4.1 (A)(11) and (A)(10) of the Code, [e]xcept as permitted by law,*[] or by Rules 4.2, 4.3, and 4.4, a judge or a judicial candidate* shall not: . . . 10. make any statement that would reasonably be expected to affect the outcome or impair the fairness of a matter pending* or impending* in any court; or 11. in connection with cases, controversies, or issues that are likely to come before the court, make pledges, promises, or commitments that are inconsistent with the impartial* performance of the adjudicative duties of judicial office. W. Va. Jud. Code R. 4.1(A)(10)–(11). The Code defines a “Pending Matter” as “a matter that has commenced” or “continues to be pending through any appellate process until final disposition.” (ECF No. 21-2 at 2.) Likewise, an “Impending Matter” is defined as a “matter that is imminent or expected to occur in the near future.” (ECF No. 21-2 at 1.) Violation of Rule 4.1(A)(10) and (A)(11) may result in “admonishment; reprimand; censure; suspension without pay for up to one year for each violation; a fine of up to $5,000.00 for each violation; and/or where applicable, suspension or annulment of a law license.” (ECF No. 21-2 at 10 (citing W. Va. R. of Discip. Proc. 2.2, 4.12).) Plaintiff moves this Court for a temporary restraining order and/or temporary or permanent injunction against Defendants because—he alleges—if Defendants were not enjoined from 2 enforcing Rule 4.1(A)(10) and (A)(11), “Plaintiff would suffer a restriction on his ability to communicate with voters before a statewide election to be held in May of 2026.” (ECF No. 12 at 2, ¶ 9.) Plaintiff filed his motion1 on March 12, 2026. (ECF No. 11). Pursuant to the Court’s order, (ECF No. 16), on March 20, 2026, Defendants filed a response, (ECF No. 18), and the Court

held a hearing on the motion on March 25, 2026, (ECF No. 21). At the hearing, Plaintiff admitted two exhibits. (ECF No. 21.) As such, the matter is fully briefed and ripe for adjudication. II. LEGAL STANDARD “The standard for deciding an application for a temporary restraining order is identical to that for deciding a motion for preliminary injunction.” Courtland Co. v. Union Carbide Corp., No. 2:21-cv-00101, 2021 WL 1255416, at *7 (S.D. W. Va. April 5, 2021) (Copenhaver, J.). Accordingly, to prevail on either, “the plaintiff must establish ‘[1] that he is likely to succeed on the merits, [2] that he is likely to suffer irreparable harm in the absence of preliminary relief, [3] that the balance of equities tips in his favor, and [4] that an injunction is in the public interest.’”

Real Truth About Obama, Inc. v. FEC, 575 F.3d 342, 346 (4th Cir. 2009) vacated on other grounds, 559 U.S. 1089 (2010), remanded to, 607 F.3d 355, 355 (4th Cir. 2010) (reinstating relevant part) (quoting Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008)). The Plaintiff must establish all four factors “by a ‘clear showing’” before the injunction will issue. Imagine

1 Noticeably absent from Plaintiff’s bare bones complaint, (ECF No. 1), and motion, (ECF Nos. 11, 12), is any express contention by Plaintiff that he actually desires to engage in speech prohibited by Rule 4.1 of the Code. Indeed, Plaintiff hints at a desire to engage in speech prohibited by Rule 4.1, stating that enforcement of the Rule would “adversely affect” and “violat[e]” his First Amendment rights and that the existence of Rule 4.1 “constitutes a[] threat of enforcement against the Plaintiff.” (ECF No. 1 at 3–4, ¶¶ 12, 14, 16; see also ECF No. 12 at 2, ¶¶ 5, 9 (alleging that enforcement of the Rule would “adversely affect” his First Amendment rights and “constitute[] a[] threat of enforcement”)). Yet none of his filings express his desire to engage in speech prohibited by Rule 4.1. Nevertheless, Plaintiff finally made this desire known at the March 25, 2026, motion hearing. 3 Medispa, LLC v. Transformations, Inc., 999 F. Supp. 2d 862, 868 (S.D. W. Va. 2014) (quoting Real Truth About Obama, Inc., 575 F.3d at 346). III. DISCUSSION “When ‘the irreparable harm that [the plaintiff] has alleged is inseparably linked to his claim of a violation of his First Amendment rights . . . analysis of [the plaintiff's] likelihood of

success on the merits’ becomes the first and the most important factor for a court to consider.” Ctr. For Individual Freedom, Inc. v. Ireland, No. 1:08-00190, 2008 WL 1837324, at *2 (S.D. W. Va. April 22, 2008) (Faber, J.) (quoting Newsom ex rel. Newsom v. Albemarle County Sch. Bd., 354 F.3d 249, 254-55 (4th Cir. 2003); see also Aamer v. Obama, 742 F.3d 1023 (D.C. Cir. 2014) (stating that likelihood of success on the merits is the “most important factor”); Jones v. Caruso, 569 F.3d 258, 277 (6th Cir. 2009) (“the ‘likelihood of success’ prong is the most important to our analysis and often determinative in First Amendment cases”); Bird v. Bonta, 81 F.4th 1036, 1040 (9th Cir. 2023) (“The first [Winter] factor ‘is a threshold inquiry and is the most important factor.’” (quoting Env’t Prot. Info. Ctr. v. Carlson, 968 F.3d 985, 989 (9th Cir. 2020)).

Thus, the Court dedicates most of its analysis below to Plaintiff’s likelihood of success on the merits. A. Likelihood of Success on the Merits Plaintiff argues that Rule 4.1(A)(10) and (A)(11) function as a prior restraint on his speech under Citizens United v.

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Martin P. Sheehan v. West Virginia Judicial Investigation Commission, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-p-sheehan-v-west-virginia-judicial-investigation-commission-et-wvsd-2026.