Issue: What is necessary for a plaintiff to be entitled to temporary injunctive relief in Minnesota?
|Area of Law:||Litigation & Procedure|
|Keywords:||Temporary injunctive relief; Legal remedy; Injury|
To be entitled to any temporary injunctive relief, the harm plaintiff is likely to suffer must be irreparable; injuries alone are not enough. Morse v. City of Waterville, 458 N.W.2d 728, 729 (Minn. Ct. App. 1990); Smith v. Peoples Nat’l Bank of Mora, No. 92-956 (Minn. Ct. App. May 14, 1996). The legal remedy—damages—must be inadequate.
Irreparable harm occurs when a party has no adequate legal remedy. Mere injuries, however substantial, in terms of money, time and energy necessarily expended in the absence [of a temporary injunction], are not enough. The possibility that adequate compensatory or other corrective relief will be available at a later date, in the ordinary course of litigation, weighs heavily against a claim of irreparable harm.
Bromen Office 1 Inc. v. Coens, No. 04-046 (Minn. Ct. App. Dec. 28, 2004). Put another way, “[w]here the injury alleged is primarily economic, grounds for a temporary injunction are not established.” Id.