Goldner v. Ralph Edwards/Stu Billett Productions
- Analisa Torres
- 1:20-cv-02764
- U.S. District Court · Southern District of New York
- 2
In Goldner v. Ralph Edwards/Stu Billet Productions, Judge Torres denied Marc Goldner’s request to stop a television episode from airing.
Marc Goldner’s request to prevent the episode from airing was denied; the defendants were not barred by this order from broadcasting it.
What happened
Goldner v. Ralph Edwards/Stu Billet Productions arose from a contract involving Marc Goldner’s appearance on an episode of “The People’s Court.” The episode was filmed on November 12, 2019, and was scheduled to air around April 10, 2020.
Goldner, who represented himself, asked the court for an emergency order preventing the episode from airing. He argued that allowing the broadcast would cause him irreparable harm.
Judge Analisa Torres treated the request as one for a temporary restraining order and denied it. The court held that stopping the broadcast would be an improper prior restraint on speech and was not in the public interest, so Goldner had not met a required condition for emergency injunctive relief.
The detailed version
- Goldner v. Ralph Edwards/Stu Billett Productions · No. 1:20-cv-02764
- Analisa Torres
- Apr. 6, 2020
Background
Marc Goldner, representing himself, sued Ralph Edwards/Stu Billet Productions, described as a television production company, and others involved in producing “The People’s Court.” The action arose from a contract between Goldner and the defendants. Goldner appeared on an episode filmed on November 12, 2019. The complaint stated that the episode was scheduled to air on or about April 10, 2020.
Goldner asked the court for a “temporary injunction” preventing the episode from airing. He argued that he would suffer irreparable harm if the episode were broadcast.
Legal standard
The court construed Goldner’s emergency request, made without notice to the opposing parties or a hearing, as a request for a temporary restraining order under Rule 65(b) of the Federal Rules of Civil Procedure. The court explained that a temporary restraining order is intended to preserve the existing situation until the court can receive more evidence about the claims. In this circuit, the standard is the same as for a preliminary injunction.
To obtain a preliminary injunction, a party must show irreparable harm, either a likelihood of success on the claims or serious questions about them combined with a balance of hardships strongly favoring the party seeking relief, and that the injunction would serve the public interest.
Court’s analysis
The court held that preventing the episode from airing would be a prior restraint. A prior restraint is a court order that suppresses speech before it occurs. The court stated that such restraints are contrary to the public interest and are among the most serious and least tolerable restrictions on speech and the press. It also stated that even speech containing factual errors or defamatory statements generally cannot be stopped in advance except in extraordinary circumstances.
Because Goldner’s requested order would be an unjustified prior restraint and would not serve the public interest, the court held that he had not satisfied one of the requirements for a preliminary injunction. The court stated that failing to prove any one required element is fatal to the request, so it did not address the remaining elements.
Disposition
The court denied Goldner’s application for a temporary restraining order. The opinion does not state that the underlying contract claims were resolved.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.