District Judge Angel Kelley: ELECTRONIC ORDER entered. Before the Court is Defendants’ Motion to Stay All Deadlines pending the First Circuit’s review of the Court’s June 12, 2026, preliminary injunction order. [Dkt. 59]. Plaintiffs oppose the Motion. [Dkt. 61]. For the following reasons, Defendants’ 59 Motion to Stay is DENIED.
Ordinarily, “[a]n appeal from the grant or denial of a preliminary injunction does not divest the trial court of jurisdiction or prevent it from taking other steps in the litigation while the appeal is pending.” Contour Design, Inc. v. Chance Mold Steel Co., 649 F.3d 31, 34 (1st Cir. 2011) (quoting 11A Wright & Miller, Federal Practice and Procedure § 2962, at 438-39 (2d ed. 1995)). District courts have inherent discretionary authority to stay pending litigation “when the efficacious management of court dockets reasonably requires such intervention.” Marquis v. F.D.I.C., 965 F.2d 1148, 1154 (1st Cir. 1992) (citing, inter alia, Landis v. N. Am. Co., 299 U.S. 248, 254-55 (1936)). That said, “stays cannot be cavalierly dispensed: there must be good cause for their issuance; they must be reasonable in duration; and the court must ensure that competing equities are weighed and balanced.” Id. at 1155. The movant “bears the burden of establishing its need.” Clinton v. Jones, 520 U.S. 681, 708 (1997).
Defendants contend that there is good cause to stay proceedings while their appeal is pending. They argue that a stay “would conserve the parties’ resources and judicial resources” because the two proceedings present “overlapping” issues, including concerns relevant to irreparable harm, standing, and the merits of Plaintiffs’ claims.
Weighing the competing interests in this case, the Court finds that the harm to Plaintiffs in staying the proceedings outweighs any harm to Defendants from denying a stay. The First Circuit has already stayed this Court’s preliminary injunction order, reducing any harm to Defendants from the relief previously ordered. At the same time, Defendants may implement the Secretary’s Order pending appeal, and Plaintiffs therefore continue to suffer meaningful harm from its implementation—even if the First Circuit ultimately determines that such harm does not rise to the level of irreparable harm necessary for a preliminary injunction.
The only harm Defendants articulate is the burden of litigating this case. But merely “being required to defend a suit, without more, does not constitute a ‘clear case of hardship or inequity.’” Ctr. for Biological Diversity v. Ross, 419 F. Supp. 3d 16, 21 (D.D.C. 2019) (quoting Landis, 299 U.S. at 255). Moreover, the litigation remains at an early stage. The only pending obligation is for counsel to submit a proposed schedule for preparing the administrative record, extra-record discovery, if necessary, and summary judgment briefing. There is no imminent trial, final judgment, or other particularly burdensome procedural step in the immediate future. The Court thus declines to exercise its discretion to stay the proceedings at this time.
Defendants’ invocation of Coinbase, Inc. v. Bielski, 599 U.S. 736 (2023), does not alter this conclusion, as the Supreme Court’s holding in that case “reaches only arbitration appeals under § 16(a)” of the Federal Arbitration Act. Id. at 761 (Jackson, J., dissenting). That context is inapplicable here.
Accordingly, Defendants’ Motion to Stay All Deadlines is DENIED.
(CEH)