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Irreparable harm is traditionally defined as harm for which there is no adequate legal remedy, such as an award of damages. Because intangible injuries generally lack an adequate legal remedy, intangible injuries may qualify as irreparable harm.
The federal government has enacted a program called "Deferred Action for Childhood Arrivals" ("DACA"), which authorizes certain immigrants who came to the United States as children, without permission, to remain in the United States. In response, Arizona officials — Defendants here — implemented a policy that prevents DACA recipients from obtaining Arizona driver's licenses.
Plaintiffs — five individual DACA recipients living in Arizona, plus an organization promoting the interests of young immigrants — sought a preliminary injunction prohibiting Defendants from enforcing their policy, arguing that the policy violates the Equal Protection Clause and is preempted. The district court found that Defendants' policy deprives Plaintiffs of driver's licenses for no rational reason, and thus violates the Equal Protection Clause. The district court nonetheless denied the preliminary injunction, because it found Plaintiffs were not likely to suffer irreparable harm from this constitutional violation.
Did the district court err in finding that the DACA recipients were not likely to suffer irreparable harm from the Equal Protection Clause violation?
The court held that undocumented immigrants and a community organization should have been granted injunctive relief because they were likely to succeed on the merits of their Fourteenth Amendment equal protection claim against defendants, the Arizona Department of Transportation and state officials, as there was no legitimate state interest rationally related to defendants' decision to treat DACA recipients disparately from other noncitizens who were permitted to use their employment authorization documents as proof of their authorized presence in the United States when applying for driver's licenses, and they had shown that they were likely to suffer irreparable harm unless defendants' policy was enjoined and that both the balance of equities and the public interest favored an injunction.