Hendrix v. Garcia
- Charles Breyer
- 3:25-cv-09674
- U.S. District Court · Northern District of California
- 4
In Adam Hendrix v. Leonardo Garcia, Judge Breyer denied Hendrix’s temporary restraining order because his filings were vague and failed required procedures.
Adam Hendrix’s request for a temporary restraining order; the order did not resolve the underlying claims.
What happened
Adam Hendrix, representing himself, sued Leonardo Garcia and other defendants over a no-contact order in Illinois and the denial of San Francisco assistance benefits. He asserted constitutional, civil-rights, disability, fraud, and conspiracy claims.
Hendrix asked for an emergency temporary restraining order, but his motion consisted of two sentences and did not explain why relief was warranted. The court also found that his complaint was confusing and that his filings did not satisfy the court’s procedural requirements for requesting a temporary restraining order.
Judge Charles R. Breyer denied the motion. The court said it could not evaluate most of the required factors and that Hendrix’s statement about financial harm was conclusory and did not connect that harm to any defendant. This order addressed the temporary restraining order, not the merits of the underlying claims.
The detailed version
- Hendrix v. Garcia · No. 3:25-cv-09674
- Charles Breyer
- Dec. 2, 2025
Background
Adam Hendrix, proceeding without a lawyer, filed claims against numerous defendants. He described two injuries: the entry and later extensions of a no-contact order in Illinois, and the denial of County Adult Assistance Program benefits in San Francisco. His listed claims included alleged violations of the First and Fourteenth Amendments, fraud on the court, conspiracy under 42 U.S.C. § 1985, requests for declaratory and injunctive relief, and damages under 42 U.S.C. § 1983. The opinion states that the complaint was confusing and did not clearly identify the basis for the requested relief.
Hendrix then filed an emergency motion for a temporary restraining order, or TRO. The motion asked for emergency relief, to seal address information, and to have defendants served by the sheriff’s office. It contained only two sentences and no supporting argument. Hendrix’s emergency declaration said that losing his benefits had caused irreparable harm and that he faced immediate financial collapse.
Court’s analysis
A TRO is an extraordinary form of temporary relief. The person requesting one must show a likelihood of success on the claims, a likelihood of irreparable harm without relief, that the balance of hardships favors relief, and that an injunction would serve the public interest.
The court found that Hendrix’s motion did not meet the substantive or procedural requirements for seeking a TRO in the Northern District of California. Those requirements include a complaint, a separate legal memorandum, a proposed order and order to show cause, supporting documents, and a declaration addressing notice to the opposing party or explaining why notice was not given. The court said Hendrix submitted only his complaint as a substantive document and offered no argument explaining why a TRO should issue.
The court also said that Hendrix’s confusing and vague complaint prevented it from understanding his position and reviewing the merits of the requested relief. The court could begin to consider only the irreparable-harm factor because of Hendrix’s financial-distress allegations, but it found his declaration conclusory and did not identify any defendant’s role in causing the alleged harm.
Disposition
The court denied Hendrix’s motion for a temporary restraining order. The order did not decide the merits of Hendrix’s underlying claims. The opinion also notes that Magistrate Judge Lisa Cisneros had previously recommended dismissing the complaint and denying the TRO, and had granted Hendrix’s request to seal confidential address information; those matters are described as part of the earlier proceedings.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.