Red Mountain Diagnostics, LLC, et al. v. Black, etc., [Ms. SC-2024-0128, Sep. 20, 2024] __ So. 3d __ (Ala. 2024). The Court (Stewart, J.; Parker, C.J., and Wise, Sellers, and Cook, JJ., concur) dissolves a preliminary injunction issued by the Jefferson Circuit Court in a dispute between joint venture participants concerning proper distribution of profits. The preliminary injunction required RMD, LLC and its principals to deposit certain funds into court and further ordered them “to maintain the sum of $1,241,276.62 in the checking account in the name of RMD, LLC at Regions Bank, and … [to] not access or use these funds in any manner until further orders of the Court.” Ms. *8.
In reviewing a preliminary injunction, the Court
“Reviews de novo the trial court’s resolution of questions of law based on undisputed facts, … but review[s] the decision to enter the preliminary injunction under the excess-of-discretion standard. City of Helena v. Pelham Bd. of Educ., 375 So. 3d 750, 752 (Ala. 2022). As part of our review, we must consider whether the trial court’s decision to issue the preliminary injunction is supported by evidence in the record. Id. A party seeking a preliminary injunction must produce evidence sufficient to demonstrate all four of the following prerequisites: ‘(1) the party would suffer irreparable harm without the injunction, (2) the party has no adequate remedy at law, (3) the party has at least a reasonable chance of success on the ultimate merits of the case, and (4) the hardship that the injunction will impose on the opposing party will not unreasonably outweigh the benefit accruing to the party seeking the injunction.’ Id. (citing Holiday Isle, LLC v. Adkins, 12 So. 3d 1173, 1176 (Ala. 2008)).”
Ms. *10.
The Court reiterates that “Irreparable injury is an injury that is not redressable in a court of law through an award of money damages” and “when a plaintiff alleges a purely monetary loss and seeks only to recover monetary damages to redress that loss, the alleged injury is reparable.” Ms. *12, internal citations and quotation marks omitted. In dissolving the preliminary injunction, the Court reiterates “plaintiff’s mere allegation that, without the issuance of an injunction, a defendant might be unable to satisfy a potential judgment does not convert the plaintiff’s reparable injury into an irreparable one that justifies injunctive relief. ... There is no evidence supporting the conclusions that Black and MDL will suffer imminent, irreparable harm without an injunction or that any harm that could occur cannot be remedied by a judgment awarding damages to Black and MDL in the event they present evidence supporting their claims.” Ms. *16, internal citation and quotation marks omitted.