Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)

Citation: Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)
Parent Document: Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)
Jurisdiction: United States (federal)
Effective Date: 2018-03-01
Original Source: https://www.courtlistener.com/opinion/4473714/mary-valencia-v-city-of-springfield/ ↗

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a sliding scale approach: ‘[t]he more likely the plaintiff is to
win, the less heavily need the balance of harms weigh in his
favor; the less likely he is to win, the more need it weigh in his
favor.’” Id. (alteration in original) (quoting Roland Mach., 749
F.2d at 387). “Where appropriate, this balancing process
should also encompass any effects that granting or denying
the preliminary injunction would have on nonparties (some-
thing courts have termed the ‘public interest’).” Id. (quoting
Ty, Inc. v. Jones Grp., Inc., 237 F.3d 891, 895 (7th Cir. 1986)).
    As stated above, the City contests only a single aspect of
the preliminary injunction inquiry: whether plaintiffs are
likely to succeed on the merits. “A party moving for prelimi-
nary injunctive relief need not demonstrate a likelihood of ab-
solute success on the merits. Instead, he must only show that
his chances to succeed on his claims are ‘better than negligi-
ble.’” Whitaker, 858 F.3d at 1046 (quoting Cooper v. Salazar, 196
F.3d 809, 813 (7th Cir. 1999)). Although “[t]his is a low thresh-
old,” id., it “does not mean … that applicants for interim in-
junctive relief with relatively weak cases will always obtain
injunctions.” Sofinet v. INS, 188 F.3d 703, 707 (7th Cir. 1999).
“If it is plain that the party seeking the preliminary injunction
has no case on the merits, the injunction should be refused
regardless of the balance of harms.” Green River Bottling Co. v.
Green River Corp., 997 F.2d 359, 361 (7th Cir. 1993).
    In reviewing the grant or denial of a preliminary injunc-
tion, this court “examines legal conclusions de novo, findings
of fact for clear error, and the balancing of harms for abuse of
discretion.” Coronado v. Valleyview Pub. Sch. Dist. 365-U, 537
F.3d 791, 795 (7th Cir. 2008); see also Whitaker, 858 F.3d at 1044.
In other words, “[a] district court abuses its discretion when,
in conducting its preliminary injunction analysis, it commits
No. 17-2773                                                     11

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