Requirements for Order Granting Preliminary Injunction

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City of Trussville v. Personnel Board of Jefferson County, [Ms. 2190075, June 12, 2020] __ So. 3d __ (Ala. Civ. App. 2020). The court (Thompson, P.J.; Moore and Donaldson, JJ., concur; Edwards, J., concurs in the result; and Hanson, J., recuses) reverses a preliminary injunction issued by the Jefferson Circuit Court prohibiting the City of Trussville from forming its own civil-service system separate from the Jefferson County Personnel Board.

“[T]he trial court’s order merely recited two of the elements to be proven to warrant the granting of the preliminary injunction and did not specify its own reasons for issuing the injunction. Thus, the order does not comply with the mandatory requirements of Rule 65(d)(2), and this court is required to reverse the order issuing the preliminary injunction. As a result, ‘we need not consider whether the evidence ultimately supports the issuance of the preliminary injunction because the order is due to be reversed regardless of whether the evidence supports the issuance of the injunction.’”

Ms. *13, quoting Stephens v. Colley, 160 So. 3d 278, 283 (Ala. 2014).

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