Background
A group of individuals sued the National Collegiate Athletic Association in Louisiana’s 19th Judicial District Court for East Baton Rouge Parish. The appellate court’s brief writ disposition does not describe the underlying claims or the terms of the preliminary-injunction ruling at issue.
The Southeastern Conference and Commissioner Sankey sought supervisory review and a stay from the Louisiana Court of Appeal, First Circuit. Their application challenged the district court’s refusal to suspend proceedings or an order or judgment relating to a preliminary injunction.
The Court’s Holding
The First Circuit denied both the requested stay and the supervisory writ. Citing Louisiana Code of Civil Procedure article 3612(B) and (C), the court explained that an order or judgment concerning a preliminary injunction is not suspended during an appeal unless the court exercises its discretion to order otherwise.
The court further noted that a stay of additional proceedings is discretionary. It concluded that the Southeastern Conference and Commissioner Sankey had not shown that the district court abused its discretion.
Key Takeaways
- An appeal involving a preliminary injunction does not automatically suspend the relevant order or judgment under Louisiana law.
- Whether to stay further proceedings rests within the court’s discretion.
- Supervisory relief was unavailable because the applicants failed to demonstrate an abuse of discretion by the district court.
Why It Matters
The disposition underscores the demanding standard for obtaining appellate intervention in Louisiana after a trial court declines to stay a preliminary-injunction matter. A party seeking supervisory relief must show more than disagreement with the trial court’s decision; it must establish an abuse of discretion.