SLEDGE v. DOE et al

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
LARRY ALLEN SLEDGE, )
) No. 2:24-cv-l 079
Plaintiff )
) RICHARD A. LANZILLO
V. ) Chief United States Magistrate Judge
)
JANE DOE, et al., ) MEMORANDUM ORDER
)
Defendants ) ECF NO. 44
Pending before the Court is Plaintiff Larry Allen Sledge's motion for preliminary
injunction [ECF No. 44]. Plaintiff's motion alleges that personnel at the State Correctional
Institution at Fayette, where he is incarcerated, have withheld, or otherwise failed to deliver, books
he ordered through the mail that he requires to complete a remote paralegal class by a deadline of
November 20, 2025. See ECF No. 44, pp. 1-2. He seeks "injunctive relief for the $60.00 he paid
on 9-26-2025, and to be compensated for the amount of the program in the amount of $1000.00,
as he will not be able to complete the program ... and compensated for emotional distress from not
completing his new career as a paralegal .. . ". Id., p.2. For the following reasons,Plaintiffs motion
will be DENIED.
The Court considers four factors in assessing a motion for a preliminary injunction. They
are: (I) whether the movant has shown a reasonable probability of success on the merits; (2)
whether the movant will be irreparably injured by denial ofrelief; (3) whether granting preliminary
relief will result in even greater harm to the nonmoving party; and (4) whether granting the
preliminary relief will be in the public interest. Council ofAlternative Political Parties v. Hooks,
121 F.3d 876,879 (3d Cir. 1997) (citing American Civil Liberties Union of New Jersey v. Black
Horse Pike Regional Bd. of Educ., 84 F.3d 1471, 1477 n. 2 (3d Cir.1996) (in bane)). The first two
Case 2:24-cv-01079-RAL Document 47 Filed 11/19/25 Page 1 of 3

factors are the "most critical." Reilly v. City of Harrisburg, 858 F.3d 173 , 178 (3d Cir. 2017), as
amended (June 26, 2017) (quoting Nken v. Holder, 556 U.S. 418,434 (2009)). Only if the movant
satisfies these "gateway factors" will "a court then considers the remaining two factors and
determines in its sound discretion if all four factors, taken together, balance in favor of granting
the requested preliminary relief." Id.
Plaintiffs motion fails because its own allegations demonstrate that he seeks purely
compensatory damages for past harm, not relief to prevent imminent, irreparable future harm. This
forecloses the entry of a preliminary injunction. 	See Boyd v. Larson, 2017 WL 1904278, at *3
(M.D. Pa. Apr. 21 , 2017) (holding that " [a] preliminary injunction cannot be issued based on past
harm") (quoting Fischer v. Goord, 981 F. Supp. 140, 168 (W.D.N.Y. 1997)). Acierno v. New
Castle County, 40 F.3d 645, 653 (3d Cir. 1994); ECRI v. McGraw-Hill, Inc., 809 F.2d 223, 226
(3d Cir. 1987) (preliminary injunctive relief may only issue where the injury is of a "peculiar
nature, so that compensation in money cannot atone for it"); Instant Air Freight Co. v. CF. Air
Freight, Inc., 882 F .2d 797, 801 (3d Cir. 1989) (plaintiff must allege an injury that cannot
ultimately be "redressed by a legal or an equitable remedy following trial").
Plaintiffs motion also must be denied because it is not tethered to the claims asserted in
his operative Second Amended Complaint [ECF No. 22]. The Second Amended Complaint asserts
constitutional and state law claims based on allegations that the named defendants acted with
deliberate indifference to his serious medical needs. 	These claims are entirely distinct from the
interference with his mail claim underlying his motion for injunctive relief. 	The purpose of a
preliminary injunction is "merely to preserve the relative positions of the parties until a trial on the
merits can be held." St . Thomas-St. John Hotel & Tourism Ass'n. Inc. v. Gov 't of US. Virgin
Islands ex rel. Virgin Islands Dept. of Labor, 357 F.3d 297, 301 (3d Cir. 2004). Consequently, a
2
Case 2:24-cv-01079-RAL Document 47 Filed 11/19/25 Page 2 of 3

request for injunctive relief "must, of necessity, bear a relationship to the underlying merits of the
suit." Straton v. Tony, 2006 WL 3840802, at *2 (W.D. Pa. Dec. 22, 2006) (citing Devose v.
Harrington, 42 F.3d 470,471 (8th Cir. 1994)). No such relationship exists here.
Plaintiffs motion for preliminary injunctive relief this there(ore DENIED.
SO ORDERED, this 19th day ofNovember, 2025 .
BY THE COURT:
Chief United States Magistrate Judge
3
Case 2:24-cv-01079-RAL Document 47 Filed 11/19/25 Page 3 of 3