Brown v. World Health Organization
- Laura Swain
- 1:24-cv-07216
- U.S. District Court · Southern District of New York
- 2
In Brown v. World Health Organization, Judge Swain denied Brown’s requests for preliminary relief because her filings did not meet the required merits showing.
Sharon Brown’s requests for preliminary injunctive relief were denied; the opinion names the World Health Organization and other defendants but does not describe the underlying claims.
What happened
In Brown v. World Health Organization, Sharon Brown, representing herself, asked the court for immediate preliminary relief through three requests for orders to show cause.
The court explained that this extraordinary relief requires a likely irreparable injury and either a likely win on the merits or serious questions supporting the case and a strongly favorable balance of hardships. The court found that Brown’s filings did not satisfy the required merits showing and denied all three requests.
Judge Laura Taylor Swain denied the requests and said the court would issue a more detailed explanation later. She also ruled that any appeal would not be taken in good faith and denied permission to appeal without paying court fees.
The detailed version
- Brown v. World Health Organization · No. 1:24-cv-07216
- Laura Swain
- Dec. 6, 2024
Background
Sharon Brown, proceeding without a lawyer, filed three requests for orders to show cause seeking preliminary injunctive relief. The opinion does not describe the underlying claims or specify what relief Brown sought.
Legal standard
The court stated that preliminary injunctive relief is an extraordinary remedy. To obtain it, a plaintiff must show that she is likely to suffer irreparable harm and either that she is likely to succeed on the merits or that there are sufficiently serious questions for litigation, together with a balance of hardships that strongly favors her.
Ruling
The court found that Brown’s submissions did not demonstrate a likelihood of success on the merits or sufficiently serious questions supported by a strongly favorable balance of hardships. It therefore denied Brown’s requests for orders to show cause, identified as ECF Nos. 3, 5, and 8. The court stated that it would issue an explanatory order later.
The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from this order would not be taken in good faith. It therefore denied permission to appeal without paying court fees for purposes of an appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.