Benisek v. Lamone

The district court did not abuse its discretion by denying Petitioners’ motion for a preliminary injunction because the balance of equities and the public interest tilted against the motion.

Six years following the redrawing of Maryland’s Sixth Congressional District, Petitioners moved to enjoin election officials from holding elections under the congressional district map. Petitioners argued that the alleged gerrymandering was conducted to retaliate against Republican voters for their political views. The district court denied Petitioners’ motion finding that Petitioners did not show a likelihood of success on the merits. On appeal, Petitioners argued that the district court abused its discretion by denying its preliminary injunction motion. The Supreme Court affirmed the district court’s decision, holding that the court did not abuse its discretion. The Supreme Court reasoned that when a party seeks a preliminary injunction, the court must consider whether the moving party showed “that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.”  The Supreme Court found that the years-long delay in seeking injunctive relief and the public’s interest in orderly elections weighed against Petitioners’ request. Furthermore, the Supreme Court found that it was within the discretion of the district court to conclude that a preliminary injunction might have caused disruption on the electoral process. Therefore, the district court’s denial of Petitioners’ motion was not an abuse of discretion. AFFIRMED