OLIVER v. OLIVER

CourtDistrict Court, M.D. Georgia
DecidedApril 17, 2025
Docket5:24-cv-00426
StatusUnknown

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

Bluebook
OLIVER v. OLIVER, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION

ANTHONY OLIVER, : : Plaintiff, : Case No. 5:24-CV-00426-TES-CHW : v. : : Commissioner TYRONE OLIVER, : et. al., : Proceedings Under 42 U.S.C. §1983 : Before the U. S. Magistrate Judge Defendant. :

ORDER AND RECOMMENDATION Pro se Plaintiff Anthony Oliver, a prisoner in Wheeler Correctional Facility in Alamo, Georgia, filed a civil rights complaint in the Superior Court of Monroe County, which the Defendants have removed to this Court. ECF No. 4. The action seeks declaratory and injunctive relief, as well as damages based on Defendants’ alleged violations of the Americans with Disabilities Act and the Rehabilitation Act, the Fourteenth Amendments of the United States Constitution, and state law. It appears Plaintiff was able to serve her1 complaint on Defendant Oliver. ECF No. 4-1 at 37. Although it does not appear that the complaint has been served upon any other Defendant, all Defendants have filed an answer. Id. at 41-57. Defendants also filed a

1 Plaintiff interchangeably uses male and female pronouns in pleadings and motions. See ECF Nos. 4 and 6. However, Plaintiff identifies as a “transgender woman” and more often uses female pronouns. See id. Accordingly, the Court adopts Plaintiff's preferred usage of female identifiers. notice of removal under 28 U.S.C. §§ 1441 and 1446 on behalf of all named Defendants and paid the $405.00 filing fee. ECF No. 4 at 1-4. This civil action is ripe for preliminary

review. Plaintiff has filed a motion requesting a “show cause” hearing. ECF No. 5. Plaintiff’s request for a hearing is premature and is DENIED as such. Plaintiff has also filed a motion for a preliminary injunction. ECF No. 6. For the reasons set forth below, it is RECOMMENDED that the motion for preliminary injunction be DENIED.

PLAINTIFF’S REQUEST FOR A PRELIMINARY INJUNCTION A preliminary injunction or temporary restraining order (“TRO”) is a drastic remedy used primarily to preserve the status quo rather than grant most or all of the substantive relief sought in the complaint. See, e.g., Cate v. Oldham, 707 F.2d 1176, 1185 (11th Cir. 1983); Fernandez-Roque v. Smith, 671 F.2d 426, 429 (11th Cir. 1982). The standard for obtaining both types of relief is the same. See Parker v. State Bd. of

Pardons & Paroles, 275 F.3d 1032, 1034-35 (11th Cir. 2001) (per curiam); Windsor v. United States, 379 F. App’x 912, 916-17 (11th Cir. 2010) (per curiam). A movant seeking a preliminary injunction or a TRO must show: (1) substantial likelihood of success on the merits; (2) irreparable injury will be suffered unless the injunction issues; (3) the threatened injury to the movant outweighs whatever damage the proposed

injunction may cause the opposing party; and (4) if issued, the injunction would not be adverse to the public interest. McDonald’s Corp. v. Robertson, 147 F.3d 1301, 1306 (11th Cir. 1998) (citations omitted); see also Ingram v. Ault, 50 F.3d 898, 900 (11th Cir. 1995) (per curiam). “‘A preliminary injunction is an extraordinary and drastic remedy not to be granted unless the movant clearly establishes the “burden of persuasion” as to the four requisites.’” All Care Nursing Serv., Inc. v. Bethesda Mem. Hosp., Inc., 887 F2d.

1535, 1537 (11th Cir. 1989) (citations omitted). Furthermore, the Prison Litigation Reform Act (“PLRA”) mandates that injunctive relief is only appropriate where it is “narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.” 18 U.S.C. § 3626(a)(1)(A). See Thomas v. Bryant, 614 F.3d 1288, 1318, 1324 (11th Cir. 2010).

Plaintiff has not met the burden of persuasion on all four requisites for obtaining injunctive relief. Specifically, Plaintiff has failed to establish that there is a substantial likelihood that she will prevail on the merits of her claim or that irreparable injury will be suffered unless the injunction issues. As to the substantial likelihood that she will prevail on her claims, federal law is unsettled as to whether “gender dysphoria” or “gender

identity disorders” are qualifying disabilities under the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act (“RA”). Particularly, the ADA excludes gender identity disorders from protection under § 12111. In 2022, the Fourth Circuit carved out an exception for gender dysphoria manifested through physical impairments as a qualifying disability under the American Disabilities Act. Williams v. Kincaid, 45 F.4th

759, 770 (4th Cir. 2022). It is the only Circuit Court to have done so. There is a considerable amount of litigation, and executive branch actions are presently evolving as to whether gender dysphoria is a qualifying disability under the ADA. See State of Texas, et al. v. Becerra, Case No. 5:24-cv-00225-H (N.D. Tx., filed Sep. 26, 2024); Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance; Clarification, 90 Fed. Reg. 15412 (Apr. 10, 2025) (issuing the

opinion of the U.S. Department of Health and Human Services that gender dysphoria is not a qualifying disability under the ADA). The Eleventh Circuit has also recently held that persons identifying as transgender are not a suspect class for Equal Protection purposes and has denied the Equal Protection claims of transgender persons. See, e.g. Corbitt v. Sec'y of the Ala. L. Enf't Agency, 115 F.4th 1335, 1341 (11th Cir. 2024); Eknes- Tucker v. Governor of Alabama, 114 F.4th 1241, 1262 (11th Cir. 2024) (affirmatively

stating in the concurrence that “transgender status is not a classification protected by the Equal Protection Clause.”). Given the state of the law, Plaintiff has not shown at this early stage in litigation that there is a substantial likelihood that Plaintiff will prevail on the merits of her claims. In order to establish the irreparable injury requirement, Plaintiff must show that

the threat of injury is “neither remote nor speculative, but actual and imminent.” Northeastern Fla. Chapter of Ass'n of General Contractors of Am. v. City of Jacksonville, Fla., 896 F.2d 1283, 1285 (11th Cir.1990) (quoting Tucker Anthony Realty Corp. v. Schlesinger, 888 F.2d 969, 973 (2d Cir.1989)); see also Church v. City of Huntsville, 30 F.3d 1332, 1337 (11th Cir.1994) (In order to obtain injunctive relief, a plaintiff must

show “a real and immediate—as opposed to a merely conjectural or hypothetical-threat of future injury.”). At the pleading stage, Plaintiff's speculative and conclusory allegations are insufficient to establish a substantial likelihood of irreparable injury should she not be allowed to be transferred immediately and specifically to a transitional center. See Bruce v. Reese, 431 F. App'x 805, 807 (11th Cir. 2011) (affirming the denial of a preliminary injunction when the inmate did not provide any facts indicating that he would suffer

further injury); Knop v. Gordy, No. 5:16cv1356, 2017 WL 5078056, at *10 (N.D. Ala.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ramon Badillo v. Janet Thorpe
158 F. App'x 208 (Eleventh Circuit, 2005)
Jamil A. Al-Amin v. James E. Donald
165 F. App'x 733 (Eleventh Circuit, 2006)
Richard Wayne Biester v. Warden James Lanier
249 F. App'x 782 (Eleventh Circuit, 2007)
Tim Kramer v. James E. Donald
286 F. App'x 674 (Eleventh Circuit, 2008)
Erik Sanchez v. Director McCray
349 F. App'x 479 (Eleventh Circuit, 2009)
Ingram v. Ault
50 F.3d 898 (Eleventh Circuit, 1995)
McDonald's Corp. v. Robertson
147 F.3d 1301 (Eleventh Circuit, 1998)
Byron Ashley Parker v. The State Board of Pardons
275 F.3d 1032 (Eleventh Circuit, 2001)
William Mitchell v. Phillip Morris Incorporated
294 F.3d 1309 (Eleventh Circuit, 2002)
Shotz v. City of Plantation, FL
344 F.3d 1161 (Eleventh Circuit, 2003)
Sweet v. Secretary, Department of Corrections
467 F.3d 1311 (Eleventh Circuit, 2006)
Steven M. Bircoll v. Miami-Dade County
480 F.3d 1072 (Eleventh Circuit, 2007)
Miller v. Donald
541 F.3d 1091 (Eleventh Circuit, 2008)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Meachum v. Fano
427 U.S. 215 (Supreme Court, 1976)
Moody v. Daggett
429 U.S. 78 (Supreme Court, 1976)
Hewitt v. Helms
459 U.S. 460 (Supreme Court, 1983)
Hafer v. Melo
502 U.S. 21 (Supreme Court, 1991)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
OLIVER v. OLIVER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliver-v-oliver-gamd-2025.