Legal Memorandum: Temporary Injunctive Relief in MN

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
Jurisdiction: Minnesota
Cited Cases: None
Cited Statutes: None
Date: 07/01/2013

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.