KNIGHT v. MACON HOUSING AUTHORITY

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
DESIREE KNIGHT, 	)
)
Plaintiff, 	)
)
v. 	) 	CIVIL ACTION NO. 5:25-cv-366 (MTT)
)
MACON HOUSING AUTHORITY, 	)
)
)
Defendant. 	)
)
ORDER
Knight filed a motion for a temporary restraining order (“TRO”) and a motion to
proceed in forma pauperis (“IFP”) on August 27, 2025. ECF 1; 2. She filed a complaint
on September 9, 2025. ECF 3. The Court granted Knight’s motion to proceed IFP and
ordered Knight to file an amended complaint, which she did. ECF 5; 7. On November
21, 2025, the Court dismissed the Fair Housing Act (“FHA”) and Rehabilitation Act
claims in Knight’s amended complaint but allowed her due process claim against Macon
Housing Authority (“MHA”) to go forward. ECF 9. The Court now considers Knight’s
motion for a TRO. ECF 1.
A TRO or preliminary injunction is a drastic remedy used primarily to preserve
the status quo rather than grant most or all of the substantive relief sought in the
complaint.1 See, e.g., Cate v. Oldham, 707 F.2d 1176, 1185 (11th Cir. 1983);
Fernandez-Roque v. Smith, 671 F.2d 426, 429 (11th Cir. 1982). To obtain a TRO, a
1 The standard for obtaining a TRO is the same as the standard for obtaining a preliminary
injunction. See Parker v. State Bd. of Pardons & Paroles, 275 F.3d 1032, 1034-35 (11th Cir. 2001) (per
curiam); Windsor v. United States, 379 F. App'x 912, 916-17 (11th Cir. 2010) (per curiam).
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plaintiff must demonstrate: (1) a substantial likelihood of success on the merits; (2) that
irreparable injury will be suffered if the relief is not granted; (3) that the threatened injury
outweighs the harm the relief would inflict on the non-movant; and (4) that granting the
relief would not be adverse to the public interest. Schiavo ex rel. Schindler v. Schiavo,
403 F.3d 1223, 1225-26 (11th Cir. 2005).
The Court has already screened Knight’s amended complaint and dismissed her
FHA and Rehabilitation Act claims, which were based on more detailed and current
versions of the facts alleged in her motion for a TRO. Compare ECF 1 at 1-2 (alleging
Knight’s inspection and transfer requests and application for a minimum rent hardship
exemption and MHA responses); ECF 7 at 1-2 (same). The only claim going forward is
Knight’s due process claim, which rests on Knight’s allegation that the minimum rent
hardship exemption hearing held on September 23, 2025 was presided over by a MHA
employee rather than an impartial party. See ECF 9 at 8. At the time Knight filed her
motion for a TRO, this hearing and the alleged violation had not yet occurred.
Accordingly, Knight’s motion for a TRO fails to establish a substantial likelihood of
success on the merits and her motion for a TRO (ECF 1) is DENIED.2
SO ORDERED, this 12th day of December, 2025.
S/ Marc T. Treadwell
MARC T. TREADWELL, JUDGE
UNITED STATES DISTRICT COURT
2 The Court need not discuss the other elements of the TRO/preliminary injunction standard. See Four
Seasons Hotels & Resorts, B.V. v. Consorcio Barr, S.A., 320 F.3d 1205, 1210 (11th Cir. 2003) (stating
that the moving party is not entitled to a preliminary injunction unless it establishes its burden as to all four
prerequisites).
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