Haley v. Forcelle

FORSBERG, Judge

(dissenting).

I respectfully dissent. Unlike the majority, I believe the district court abused its discretion in granting respondents’ motion for temporary injunctive relief because respondents failed to show that they were subject to irreparable harm. “The party seeking an injunction must establish that legal remedies are inadequate and that an injunction must issue to prevent great and irreparable injury.” Metro. Sports Facilities Comm’n v. Minn. Twins P’ship, 638 N.W.2d 214, 222 (Minn.App.2002), review denied (Minn. Feb. 4, 2002). The loss of income and financial hardship resulting from the termination of an employment relationship generally does not *62constitute irreparable injury sufficient to provide a basis for temporary injunctive relief. Miller v. Foley, 317 N.W.2d 710, 713 (Minn.1982) (stating that insufficiency of savings is common for most discharged employees and will not support a finding of irreparable injury).

This case is nothing more than a typical employment matter. Jack Haley is used to a certain lifestyle and has certain financial obligations that he must fulfill. Clearly, his termination and the accompanying loss of income would affect his ability to maintain his lifestyle and meet his financial obligations. But Jack Haley’s financial hardship is insufficient to demonstrate irreparable injury.

Respondents assert that this case is more than an employment matter because the Haleys would be left with no voice in management, no role as employees, and no way to protect their interests in Stellar Technologies, Inc. But, forcing Stellar to pay Jack Haley a salary until trial does not give him a voice in management or a way to protect his or his ex-wife’s interest in Stellar. It only relieves Jack Haley of the financial hardship of his termination. Temporary injunctive relief is not an appropriate remedy to relieve him of the financial hardship of his termination because there is an adequate remedy at law in the form of money damages at trial.

On this record, unlike the majority, I would reverse the district court and conclude that the court abused its discretion in granting respondents’ motion for injunc-tive relief because respondents failed to demonstrate that they were subject to irreparable harm.