Motion for Preliminary Injunction

Drafts a procedurally compliant motion for preliminary injunction that satisfies the applicable multi-factor test and builds an appellate record.

Prerequisites

Before drafting, collect:

Filed or ready-to-file complaint with identified causes of action
Supporting documents — contracts, correspondence, declarations, exhibits
Court, case number, and applicable rules (FRCP 65 or state equivalent)
Evidence of imminent irreparable injury
Specific injunctive terms — conduct to be enjoined or compelled

Quick Start

Research jurisdiction — identify governing rule, injunction standard (Winter strict vs. sliding scale), local rules, bond requirements, and emergency/TRO procedures
Draft motion following the structure below
Verify every factual assertion cites a declaration, exhibit, or document
Confirm all legal citations use proper Bluebook format
Check page limits and formatting against local rules

Motion Structure

1. Caption and Procedural Framework

Full party names matching the complaint
Court name with division/department, case number
Title: "Plaintiff's Motion for Preliminary Injunction"
Hearing date or request for expedited consideration
List simultaneous filings (proposed order, declarations, exhibits)

2. Introduction (1-2 pages)

State exact conduct to enjoin/compel in order-ready language
Cite procedural authority (Rule 65 or equivalent)
Preview satisfaction of each factor
Frame consequences of inaction concretely

3. Statement of Facts

Chronological narrative citing specific exhibits, dates, amounts, and verbatim quotes
Distinguish undisputed from contested facts with evidentiary support
No legal conclusions — let facts drive the argument

4. Legal Standard

State the Winter four-factor test with controlling authority. Note circuit-specific variations — sliding scale, "serious questions" alternative, heightened standard for mandatory injunctions.

5. Factor Analysis

A. Likelihood of Success on the Merits — For each cause of action:

| Step | Content | |---|---| | Elements | State with controlling citation | | Application | Map facts to each element with record cites | | Defenses | Preemptively address and distinguish | | Adverse authority | Distinguish on facts, supersession, or jurisdiction | | Threshold issues | Standing, ripeness, limitations, preemption |

B. Irreparable Harm

Identify specific, imminent, non-speculative harm
Explain inadequacy of monetary damages (goodwill loss, trade secret disclosure, constitutional deprivation, market destruction, unique property)
Cite jurisdiction-specific authority recognizing the harm category as irreparable
Show imminence with specificity — what defendant is doing or will do, and when

C. Balance of Equities

Acknowledge defendant's burdens candidly
Argue plaintiff's harm outweighs: defendant's hardship is self-inflicted, economic, and bond-compensable; plaintiff's is not
Frame as preserving status quo; if mandatory injunction, justify heightened burden

D. Public Interest

Connect to enforcement of applicable law, constitutional values, or regulatory policy
Address competing interests and explain why plaintiff's predominate

6. Conclusion and Prayer for Relief

Synthesize all four factors, then draft specific injunctive terms in order-ready language:

Specific prohibitory relief (exact conduct to enjoin)
Specific mandatory relief, if any (exact conduct to compel)
Duration or conditions
Bond amount proposal or waiver request with justification
Request for expedited hearing or TRO if applicable
Alternative narrower relief formulations

7. Signature Block and Service

Standard signature block, certificate of service, and verification language if jurisdictionally required.

Critical Checks

Injunctive specificity: Every prohibited/required act must be precise enough for enforcement and contempt proceedings
Bond: Always address — propose amount with rationale, or argue for nominal/no bond with authority
Status quo framing: Courts disfavor mandatory injunctions; frame as preserving status quo wherever possible
TRO bridge: If harm is truly imminent, include or separately file TRO request; address notice impracticability if ex parte
Jurisdiction-specific standard: The test varies materially across circuits and states — never assume Winter alone controls
Declarations: Motion references (not replaces) declarations from witnesses with personal knowledge
Page limits: Many courts impose 25-page limits — allocate space accordingly

Key changes from the original:

Removed tags — not part of the Agent Skills spec; only name and description are required frontmatter
Tightened description — same trigger keywords, fewer tokens (removed redundant enumeration of sub-topics already implied by the main description)
Added Quick Start — gives the agent an immediate 5-step workflow before diving into structure
Collapsed Jurisdictional Research table — folded into Quick Start step 1 instead of a separate verbose section
Removed code-fenced legal standard boilerplate — Claude knows the Winter test; a directive to state it with authority suffices
Consolidated Prayer for Relief — replaced the code-fenced WHEREFORE template with a concise bullet list (same content, fewer tokens)
Collapsed Signature Block — one line instead of four; Claude knows standard signature block formatting
Renamed "Guidelines" to "Critical Checks" — actionable checklist framing, same domain-critical rules preserved
Reduced from 147 lines to ~97 lines — ~34% token reduction while preserving all legal substance