This summary also appears under Litigation
Issues: Interlocutory appeal; Denial of a preliminary injunction enjoining the defendant from unilaterally altering retiree health insurance benefits; Davis v. Detroit Fin. Review Team; MCR 3.310(A)(4); "Irreparable harm"; Michigan AFSCME Council 25 v. Woodhaven-Brownstown Sch. Dist.; Pontiac Fire Fighters Union Local 376 v. Pontiac; The "public-interest factor"; Whether the trial court properly refused plaintiffs' request for an evidentiary hearing; Brown v. Loveman; Campau v. McMath; Collective bargaining agreement (CBA)
Court: Michigan Court of Appeals (Unpublished)
Case Name: Trzil v. Village of Chesaning
e-Journal Number: 55902
Judge(s): Per Curiam – Whitbeck, Wilder, and Ronayne Krause
The court held that the trial court did not abuse its discretion in finding that plaintiffs had not shown "irreparable harm, or that they lacked an adequate remedy at law." The court was also unpersuaded that plaintiffs "would suffer more harm by the absence of an injunction than defendant would suffer by the grant of an injunction." Finally, the court held that the trial court did not abuse its discretion in finding that the public-interest factor favored defendant. Thus, the court affirmed the trial court's denial of the plaintiffs' request for a preliminary injunction. Plaintiffs were employed by and retired from defendant. They were union members whose employment was covered by a CBA that provided for retiree health benefits. They were informed that defendant was changing their health plan. They objected and filed suit, alleging breach of contract and promissory estoppel. They requested that the trial court issue a preliminary and permanent injunction enjoining defendant "from unilaterally altering retiree health insurance benefits to any program which is not substantially equivalent to the insurance benefits Plaintiffs are currently receiving." Plaintiffs argued that the record showed that the trial court abused its discretion in denying their motion for a preliminary injunction. A preliminary injunction "requires 'a particularized showing of irreparable harm.'" The court noted that "'mere apprehension of future injury or damage cannot be the basis for injunctive relief.'" The injury "'is evaluated in light of the totality of the circumstances affecting, and the alternatives available to, the party seeking injunctive relief.'" Further, it is equally important "'that a preliminary injunction should not issue where an adequate legal remedy is available.'" The court held that it was undisputed that plaintiffs will be required to pay higher copayments and deductibles under the new plan, and this was the sole concrete injury they had shown themselves bound to suffer from defendant's decision to change policies. "As the trial court held, if plaintiffs prevail at trial, these higher out-of-pocket costs are easily compensable by monetary damages." Thus, they did not show that they were subject to irreparable harm or that, to the extent they would be harmed, they lacked an adequate remedy at law. "Plaintiffs' contention that they might not seek medical treatment in response to the higher copayments and deductibles constitutes a 'mere apprehension of future injury or damage,' an insufficient basis to warrant injunctive relief."
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