International Union, United Automobile, Aerospace & Agricultural Implement Workers of America, UAW v. State

Defendants appeal from the grant of a preliminary injunction preventing them from eliminating certain positions within the Michigan Department of Corrections while grievances regarding the elimination of the positions were still pending. We reverse.

Whether a preliminary injunction should issue while a grievance procedure continues is determined by a four-factor analysis: (1) harm to the public interest if an injunction issues, (2) whether harm to the applicant in the absence of a stay outweighs the harm to the opposing party if a stay is granted, (3) the strength of the applicant’s…