Owens — Fourth Circuit upheld denial of preliminary injunction

Case
Jordan Owens v. United States of America
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
WYNN (Barack Obama, 2010); HARRIS (Barack Obama, 2014); FLOYD (Barack Obama, 2011)
Date Decided
July 28, 2026
Docket No.
26-1403
Topics
Preliminary Injunction; Irreparable Harm; Rule 59(e); Pro Se Litigation
Source
Read the full opinion

Background

Jordan Owens, proceeding pro se, brought an action against the United States in the U.S. District Court for the Eastern District of Virginia. The district court denied Owens’s motion for a preliminary injunction.

Owens then filed motions under Federal Rule of Civil Procedure 59(e), asking the district court to reconsider the denial. After the court denied those motions, Owens appealed both the preliminary-injunction ruling and the reconsideration rulings to the Fourth Circuit.

The Court’s Holding

In an unpublished per curiam opinion, the Fourth Circuit affirmed the district court’s orders. After reviewing the record, the appellate court found no reversible error in the district court’s determination that Owens had failed to demonstrate either a likelihood of success on the merits of his claims or irreparable harm without preliminary injunctive relief.

The court resolved the appeal without oral argument, concluding that the record adequately presented the facts and legal issues and that argument would not assist the decisional process. Because the opinion is unpublished, it is not binding precedent in the Fourth Circuit.

Key Takeaways

  • A party seeking a preliminary injunction must demonstrate, among other requirements, a likelihood of success on the merits and irreparable harm without relief.
  • The Fourth Circuit found no reversible error in the district court’s conclusion that Owens failed to establish either requirement.
  • The court also affirmed the denial of Owens’s Rule 59(e) motions seeking reconsideration of the preliminary-injunction ruling.

Why It Matters

The decision reinforces that preliminary injunctive relief requires a concrete showing on both the merits and irreparable harm. A failure to satisfy those threshold requirements can support denial of relief and affirmance on appeal.

The ruling is unpublished and therefore does not constitute binding Fourth Circuit precedent, but it illustrates the evidentiary burden litigants face when requesting immediate injunctive relief and later seeking reconsideration of its denial.

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