Laramore v. Quality Residence, LLC.

Background

Adrianne L. Laramore rented a residence on Edgerton Street in Saint Paul, Minnesota. She alleged that a vehicle crashed into the residence on January 17, 2021, damaging it and destroying some medical items and equipment belonging to her 12-year-old daughter. According to Laramore, local authorities determined that the residence was not structurally fit for habitation and ordered Quality Residence, LLC. to repair it. She alleged that repairs had not begun and that she and her family were being forced to move. She sought damages for emotional distress, pain and suffering, and related harm.

Laramore previously filed an emergency motion for an order concerning Quality Residence’s property repairs. The court denied that motion because she had not shown a likelihood of success on the merits or irreparable harm. She then filed the renewed emergency motion addressed in this order.

Legal standard

Under Federal Rule of Civil Procedure 65, a preliminary injunction is an emergency court order issued before final judgment. The court considers four factors: the likelihood that the moving party will succeed on the merits, the threat of irreparable harm, the balance between the harms to the parties, and the public interest. The moving party bears the burden of showing that each factor supports relief.

The court also noted that filings by a person representing herself without a lawyer are read liberally and held to less demanding standards than documents prepared by an attorney. Even applying that standard, the court found that Laramore’s amended complaint did not clearly identify the legal basis for her claims. It generally referred to 42 U.S.C. § 1983 and Section 8 of the United States Housing Act of 1937, but did not identify a specific federal statutory or constitutional right allegedly violated. Because the court could not evaluate her likelihood of success from those allegations, this factor weighed against an injunction.

Irreparable harm

The court held that Laramore also had not shown irreparable harm. Irreparable harm is an injury that cannot be fully compensated by money damages. Laramore’s amended complaint sought damages for emotional distress, pain and suffering, and emotional and physical harm. The court concluded that damages were an adequate legal remedy. It also found that Laramore did not explain the nature of the alleged irreparable damage, why damages were inadequate, or whether circumstances had changed since her first emergency motion.

Ruling

Because Laramore had not demonstrated either a likelihood of success on the merits or irreparable harm, the court did not address the balance-of-harms or public-interest factors. Judge Wilhelmina M. Wright denied Laramore’s renewed emergency motion for preliminary injunctive relief. The order states that judgment should be entered accordingly.