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Klayman v. Obama - 957 F. Supp. 2d 1 (D.D.C. 2013)

Rule:

When ruling on a motion for preliminary injunction, a court must consider "whether (1) the plaintiff has a substantial likelihood of success on the merits; (2) the plaintiff would suffer irreparable injury were an injunction not granted; (3) an injunction would substantially injure other interested parties; and (4) the grant of an injunction would further the public interest."

Facts:

In a separate suit, plaintiffs challenged the constitutionality and statutory authorization of certain intelligence-gathering practices by the United States government relating to the wholesale collection of the phone record metadata of all U.S. citizens. In relation to these cases were the present Motions for Preliminary Injunction of the plaintiffs seeking to bar defendants from collecting plaintiffs’ call records under the mass surveillance program, requiring defendants to destroy all of plaintiffs’ call records already collected under the program; and prohibiting defendants from querying metadata obtained through the program using any phone number or other identifier associated with plaintiffs.

Issue:

Should the plaintiffs’ Motion for Preliminary Injunction be granted?

Answer:

Yes.

Conclusion:

The Court noted that a court, when ruling on a motion for preliminary injunction, must consider "whether (1) the plaintiff has a substantial likelihood of success on the merits; (2) the plaintiff would suffer irreparable injury were an injunction not granted; (3) an injunction would substantially injure other interested parties; and (4) the grant of an injunction would further the public interest." Taking into account these requisites, the Court held that the plaintiffs have a substantial likelihood of success on their Fourth Amendment arguments, as the collection and analysis of telephony metadata constituted a search within the meaning of Fourth Amendment. If the plaintiffs’ rights were constitutionally violated, even of minimal duration, it would constitute an irreparable injury on the part of the plaintiffs. Moreover, the Government offered no real explanation as to how granting relief to the plaintiffs would be detrimental to the public interest. Hence, the Court granted the plaintiffs’ requests for an injunction.

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