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Nat'l Ass'n for Advancement of Colored People, Inc. by and through Myrtle Beach Branch v. City of Myrtle Beach, Corp.

Citation: 383 F. Supp. 3d 603Docket: CIVIL ACTION NO. 4:18-00554-MGL

Court: District Court, D. South Carolina; May 22, 2019; Federal District Court

Narrative Opinion Summary

This case involves a lawsuit by plaintiffs, including the NAACP, against the City of Myrtle Beach and its Police Department, alleging constitutional violations related to policies during Black Bike Week. The plaintiffs seek a preliminary injunction to suspend a traffic loop implemented during the event, arguing it disproportionately affects African American attendees and reflects racial discrimination. The court denies the injunction, determining that plaintiffs did not demonstrate a likelihood of success on the merits, irreparable harm, or that the balance of equities favored them. The court emphasizes that the traffic loop was justified by public safety concerns, particularly following violent incidents in past years. The court defers to the defendants' judgment, finding no evidence of discriminatory intent. Plaintiffs failed to show that the traffic loop, in place since 2015, was based on racial animus, and their claims of inconvenience and harm did not meet the standards for a preliminary injunction. Consequently, the court upholds the traffic plan as a legitimate safety measure, prioritizing the public interest in maintaining order during Memorial Day Weekend events.

Legal Issues Addressed

Discriminatory Intent in Equal Protection Claims

Application: The court evaluates whether the traffic loop was implemented with discriminatory intent against Black Bike Week attendees, finding a lack of evidence to support such a claim.

Reasoning: To establish a discriminatory violation, Plaintiffs must prove that the traffic loop was intentionally discriminatory, not merely that it impacted one group disproportionately.

Irreparable Harm in Preliminary Injunctions

Application: The court finds that Plaintiffs did not demonstrate irreparable harm resulting from the traffic loop, as their claims were insufficient to warrant an injunction.

Reasoning: Plaintiffs did not demonstrate a likelihood of suffering irreparable harm without preliminary relief, as the Court found their claims about potential discrimination, humiliation, and constitutional injury insufficient to warrant an injunction.

Judicial Deference to Governmental Decision-Making

Application: The court affords deference to the Defendants' judgment regarding public safety measures, given the absence of evidence of racial bias.

Reasoning: Substantial judicial deference is required when assessing the legitimacy of a statutory purpose, ensuring that the court respects the value judgments established by democratically elected officials.

Preliminary Injunction Requirements

Application: The court emphasizes that a preliminary injunction requires a demonstration of likelihood of success on the merits, likelihood of suffering irreparable harm, a favorable balance of equities, and alignment with the public interest.

Reasoning: Preliminary injunctions are extraordinary remedies not granted as a matter of right, necessitating proof from the requesting party by a preponderance of the evidence.

Public Safety and Governmental Actions

Application: The Defendants justify the traffic loop as necessary for public safety during Memorial Day Weekend, a rationale the court finds credible.

Reasoning: Defendants argue that their actions were motivated by public safety concerns, citing violent incidents during past Memorial Day weekends, including shootings that hindered emergency access.