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Keywords

contractlawsuitjurisdictiondamagesarbitrationinjunctionappealmotioncontractual obligation

contractdamagesinjunctionappealaffidavitmotion

Related Cases

Classic Components Supply, Inc. v. Mitsubishi Electronics America, Inc., 841 F.2d 163

Facts

Classic Components Supply filed a lawsuit in Wisconsin court against Mitsubishi Electronics America, seeking an injunction to compel Mitsubishi to continue using Classic as a distributor. Mitsubishi removed the case to federal court under diversity jurisdiction, citing a contractual obligation for arbitration. The district court ordered Classic to arbitrate and denied its request for a preliminary injunction, concluding that Classic had not shown a likelihood of success on the merits.

Classic immediately appealed and asked for an injunction pending appeal. Although this request has produced a stack of motions, affidavits, and other papers more than two inches thick, Classic has not satisfied any of the criteria for an injunction pending appeal, which its papers do not acknowledge.

Issue

Did Classic Components Supply demonstrate irreparable injury to warrant a preliminary injunction pending appeal?

One who seeks an injunction pending appeal must show irreparable injury.

Rule

A party seeking an injunction pending appeal must show irreparable injury, and injuries that are compensable in money do not qualify as irreparable.

Injuries of this sort, common consequences of broken contracts, yield damages. An injury compensable in money is not 'irreparable', so an injunction is unavailable.

Analysis

The court found that Classic did not satisfy the criteria for a preliminary injunction because it failed to demonstrate irreparable injury. Although Classic claimed that its customers were canceling orders, the court noted that such injuries are typical in contract disputes and can be compensated with damages. The court also pointed out that Classic's sales from Mitsubishi products were minimal, further undermining its claim of irreparable harm.

Because Classic has not reached first base on irreparable injury, we do not consider whether it has a plausible legal claim or whether an injunction would injure Mitsubishi more than it would help Classic.

Conclusion

The Court of Appeals denied Classic's request for an injunction pending appeal and ordered Classic to reimburse Mitsubishi for its costs in responding to the motion.

Classic's motion for an injunction pending appeal was foredoomed. It would be unjust to Mitsubishi to leave it saddled with the costs of responding to a motion that should not have been filed.

Who won?

Mitsubishi Electronics America prevailed in the case because Classic failed to demonstrate the necessary criteria for a preliminary injunction, particularly irreparable injury.

Classic, not Mitsubishi, is the author of these costs and must bear them.

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