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lawsuitinjunctionappealhearing
injunction

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Rothberg v. Law School Admission Council, 102 Fed.Appx. 122, 190 Ed. Law Rep. 145, 28 NDLR P 129

Facts

Rothberg, a senior at Syracuse University, applied for accommodations for the LSAT due to her learning disability, which affects her ability to process information. After LSAC denied her requests for accommodations, Rothberg took the LSAT without them and scored 148. She later filed a lawsuit seeking a preliminary injunction to require LSAC to provide her with fifty percent extra time for the LSAT, which the district court granted after a hearing. The court found that Rothberg had a substantial likelihood of success on her ADA claim based on the evidence presented by her clinical psychologists.

Rothberg is a senior at Syracuse University who hopes to attend law school. Throughout her education, Rothberg has received a variety of accommodations to address her learning disability, which affects her ability to process information. The LSAC is a non-profit entity that administers the LSAT, a standardized test required for application to every accredited law school in the United States.

Issue

Did the district court abuse its discretion in granting a preliminary injunction requiring LSAC to report Rothberg's accommodated LSAT score?

Did the district court abuse its discretion in granting a preliminary injunction requiring LSAC to report Rothberg's accommodated LSAT score?

Rule

To obtain a preliminary injunction, a party must establish: (1) a substantial likelihood of success on the merits; (2) irreparable injury if the injunction is denied; (3) the threatened injury to the movant outweighs the injury to the other party; and (4) the injunction is not adverse to the public interest.

To obtain a preliminary injunction, a party must clearly establish: (1) a substantial likelihood of success on the merits; (2) irreparable injury to the movant if the injunction is denied; (3) the threatened injury to the movant outweighs the injury to the other party; (4) the injunction is not adverse to the public interest.

Analysis

The Court of Appeals found that the district court failed to properly weigh the balance of harms between Rothberg and LSAC. While Rothberg claimed irreparable harm due to the denial of accommodations, the court noted that her injury was speculative and did not outweigh the permanent harm that LSAC would suffer if the injunction were granted. The court emphasized that granting the injunction would moot LSAC's arguments against providing accommodations, thus affecting LSAC's ability to defend its position.

Because we conclude that the harm to Rothberg does not outweigh the harm to LSAC, we reverse.

Conclusion

The Court of Appeals reversed the district court's order granting the preliminary injunction, concluding that the balance of harms did not favor Rothberg.

Because we conclude that the district court abused its discretion by failing to consider the injury to LSAC in its balance of harms analysis and because the harm to Rothberg does not outweigh the harm to LSAC, we reverse the order granting the preliminary injunction.

Who won?

Law School Admission Council (LSAC) prevailed because the Court of Appeals determined that the harm to LSAC outweighed the harm to Rothberg, and the district court had abused its discretion in its analysis.

Because the record below on this issue is well developed and because of the urgency associated with the parties' requests for relief, we see no reason to remand on this issue.

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