Gonye v. California Department of Motor Vehicles

Background

On July 7, 2021, Stephanie Gonye filed a complaint and an emergency motion for an injunction. Because of the relief requested, the court treated the motion as one for a temporary restraining order. Gonye was representing herself.

Gonye alleged that an unnamed friend caused NASA to take custody of her 2015 Toyota Prius on June 19, 2021, because the vehicle lacked registration tags. She also alleged that the same friend would not allow the California Department of Motor Vehicles to issue a compliant registration renewal without a software update that Gonye described as an attempted theft of the vehicle’s computer data and a possible technology transfer involving the federal government and a Japanese corporation.

Gonye asked the court to restrain the defendants from using or taking her Toyota Prius, household goods, and other personal property. She stated that the car served as her sleeping area, office, and storage facility while she looked for affordable housing.

Legal standard and analysis

The court explained that a temporary restraining order or preliminary injunction is an extraordinary remedy that is not automatically available. Under the governing standard, the person requesting relief generally must show a likelihood of success on the merits, likely irreparable harm without an injunction, that the balance of hardships favors the requested relief, and that an injunction would serve the public interest. A court may also grant relief when there are serious questions about the merits if the balance of hardships sharply favors the moving party and the other requirements are met.

The court agreed that Gonye had shown irreparable harm because she said she had been living in the car and therefore had been deprived of her home and belongings. However, the court found that she had not shown that she was likely to succeed on the merits or that there were serious questions about the merits. The court stated that Gonye’s offer to pay the amount required by the California Vehicle Code did not provide a legal basis for ordering NASA to return the car. The available opinion text also states that the court rejected her request for the car’s return under the amendments she invoked, but the excerpt does not identify all of those arguments.

Disposition

The court DENIED Gonye’s motion for a temporary restraining order WITHOUT PREJUDICE to Gonye moving for a preliminary injunction. Thus, the order denied the emergency motion while expressly leaving open the possibility of a later preliminary-injunction motion. The court did not order the defendants to return the car or other property.