Franklin Leroy Stephens v. Hazel Colley

The preliminary-injunction order in this case does not explicitly state the reasons for its issuance; instead, it can be read to incorporate, by reference, the reasons provided in Hazel Colley’s motion for injunc-tive relief.

Rule 65(d)(2), Ala. R. Civ. P., states that an “order granting an injunction shall set forth the reasons for its issuance.... ” I am concerned that this language does not necessarily preclude incorporating those reasons from another document. Specifically, I note that Rule 65(d)(2) only explicitly forbids incorporation by reference of a description of the acts to be…