Arebalo v. Apple, Inc.

Background

Joshua Arebalo brought claims against Apple under the Americans with Disabilities Act and for wrongful termination. West Coast Trial Lawyers, APLC (WCTL) initially represented Arebalo, but withdrew on December 10, 2020. Arebalo then proceeded without a lawyer. The parties finalized a settlement agreement, but Apple had not fulfilled its obligations because of a purported lien dispute between Arebalo and WCTL.

WCTL moved for a preliminary injunction—an extraordinary court order issued before final judgment—to prevent Apple from delivering the settlement payment to Arebalo until the lien dispute was resolved. WCTL also requested declaratory relief under 28 U.S.C. § 2201(a), seeking a ruling that it was entitled to the full fee under its retainer agreement with Arebalo.

Preliminary-injunction request

The court applied the standard requiring WCTL to make a threshold showing that it was likely to succeed on the merits, likely to suffer irreparable harm without an injunction, that the balance of equities favored relief, and that an injunction would serve the public interest.

The court found that WCTL had not shown a likelihood of success on its contract dispute with Arebalo. WCTL submitted no documentary evidence with its motion, including no copy of the retainer agreement. It also provided no evidence beyond its own assertion that a legally enforceable lien existed. The lien notice WCTL filed did not include an abstract of judgment issued by a court. The court therefore found no sufficient factual basis for injunctive relief.

The court also found that WCTL had not shown likely irreparable harm. WCTL argued that enforcing its rights in a separate action against Arebalo might be difficult and that Arebalo might spend the settlement funds before WCTL could obtain a judgment. The court described those assertions as speculative and unsupported by evidence. It noted that WCTL acknowledged having a separate legal remedy against Arebalo in California or Idaho, even though WCTL did not want to pursue that option.

Declaratory-relief request

The court explained that declaratory relief is a remedy based on a properly pleaded claim, not an independent cause of action. It also explained that the Declaratory Judgment Act does not itself create federal jurisdiction. WCTL’s breach-of-contract dispute with Arebalo was not before the court. To the extent WCTL relied on diversity jurisdiction for a possible contract claim, it had not provided evidence that the required amount in controversy was met. The court therefore found no basis to issue a declaration concerning the state-law contract dispute or to provide an advisory opinion about it.

Disposition

The court denied WCTL’s motion for a preliminary injunction and for declaratory relief. The court also noted that WCTL, which no longer represented Arebalo, was effectively a third party and had to enter a separate appearance. It directed WCTL not to file further submissions under Arebalo’s name.