Ryan v. Mansapit-Shimizu et al

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IN THE DISTRICT COURT OF GUAM
JOHN RYAN,
Plaintiff,
v.
DAFNE MANSAPIT-SHIMIZU, in her
individual capacity; MARIE LIZAMA in
her official and individual capacities as the
DIRECTOR OF THE GUAM
DEPARTMENT OF REVENUE AND
TAXATION, and JOHN DOES 1-15,
Defendants.
Case No. 1:23-cv-00015
DECISION AND ORDER DENYING
WITHOUT PREJUDICE
PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION
In this § 1983 civil rights action for damages and declaratory and injunctive relief, Plaintiff
John Ryan filed a Motion for a Preliminary Injunction (ECF No. 108) seeking a preliminary
injunction against “Defendant officials, in their official capacities, and those acting in concert with
them,” in view of an ongoing tax appeal proceedings in the Superior Court of Guam related to one
of Ryan’s qui tam claims brought pursuant to Guam’s False Claims and Whistleblower Act. (Mot.
for Prelim. Inj. 30, ECF No. 108.) On September 4, 2026, Defendant and current Director Marie
Lizama filed a Response (ECF No. 113), styled in the name of the Guam Department of Revenue
and Taxation (“DRT”), opposing Ryan’s Motion. Ryan filed a timely Reply (ECF No. 117). The
Court held a hearing on the Motion on September 30, 2026, before taking the matter under
advisement. For the reasons set forth below, the Court DENIES WITHOUT PREJUDICE Ryan’s
Motion and declines to issue a preliminary injunction against Defendant Lizama and DRT.
Case 1:23-cv-00015 Document 125 Filed 10/13/26 Page 1 of 12

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I. BACKGROUND
The Court has previously recounted, at length, the procedural history of this case and the
nature of Ryan’s substantive claims in deciding motions to dismiss, for judicial disqualification,
and to compel discovery. (See Decision & Order Granting Def. Villapando’s Mot. to Dismiss, &
Den. Defs. Mansapit-Shimizu & Lizama’s Mot. to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) 2-
7, ECF No. 37; Mem. Decision Den. Defs.’ Mot. for Jud. Disqualification & Granting in Part Pl.’s
Mot. to Compel 1-6, ECF No. 82.) In support of this Motion, Ryan first largely reiterates the
factual allegations underlying his Complaint:
(1) In the Superior Court of Guam, Ryan filed three qui tam actions pursuant to Guam’s False
Claims and Whistleblower Act (“Whistleblower Act,” 5 GCA §§ 37101 et seq.), alleging
that three alcohol wholesalers—Titan Imports, Inc. (“Titan”), Carson Guam Corporation
(“Carson”), and Permarch Guam, Inc. (“Permarch”)—were not paying alcohol excise taxes
as required under Guam law. (Mot. for Prelim. Inj. 10-11 [hereinafter “Pl.’s Mot.]; see also
Compl. ¶¶ 28-31, 128, 129, 139, ECF No. 1.)
(2) Though the Government of Guam declined to intervene in any of Ryan’s three qui tam
actions, DRT nonetheless compromised his claims against Titan and Carson through
negotiations, settlements, and administrative actions, all without providing Ryan with any
notice or opportunity to respond, and delayed or outright refused to pay him his share of
the proceeds as required by the Whistleblower Act. (Pl.’s Mot. 11-12; see also Compl.
¶¶ 57-138.)
As to Ryan’s still-pending qui tam action against Permarch, Ryan’s Motion represents:
(1) DRT previously conducted an “administrative assessment” of Permarch’s tax liability—
effectively determining the value of Ryan’s qui tam claim against Permarch—and made
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offers in compromise to resolve Permarch’s outstanding tax liability and penalties, all
without providing him appropriate notice as required by Guam law. (Pl.’s Mot. 12.)
(2) Permarch neither accepted any of DRT’s offers in compromise nor appealed DRT’s
“administrative assessment,” apparently because the time to appeal DRT’s assessment had
run and, according to Permarch in Ryan’s qui tam action against it, DRT allegedly had
authorized Permarch to not pay its taxes due. (Id. at 12-13.)
(3) DRT subsequently “reopened its administrative procedures”—again without providing
Ryan any notice or opportunity to participate—and made a new determination as to
Permarch’s liability. (Id at 13.) Such redetermination also apparently triggered a new
appeal period, which led to Permarch lodging an appeal (“the Tax Appeal Case”) of DRT’s
new assessment in the Superior Court of Guam sometime earlier this year. (Id. (identifying
Permarch Guam, Inc. v. Lizama, Superior Court of Guam special proceeding case number
SP0031-26).)
(4) Ryan moved to intervene in Permarch’s Tax Appeal Case in the Superior Court of Guam.
(Id.) DRT opposed intervention alongside Permarch on the ground that Ryan is not entitled
to be involved in any settlement negotiations or other resolution processes between DRT
and a taxpayer—and Ryan is owed, at most, “notice.” (Id.) The Superior Court of Guam
rejected DRT’s arguments and granted Ryan’s motion to intervene by decision and order
dated August 26, 2026. (Pl.’s Reply 10-11 (citing Pl.’s Reply Ex. N. (Decision and Order
Granting Motion to Intervene in Permarch Guam, Inc. v. Lizama, Superior Court of Guam
special proceeding case number SP0031-26), ECF No. 117-3), ECF No. 117.) DRT has
sought reconsideration of the decision and order. (Id. at 11.)
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Ryan contends that DRT’s actions as to Permarch are consistent with its previous injurious
conduct concerning Titan and Carson, namely, that DRT is attempting to resolve Ryan’s qui tam
claims in secret and in derogation of his statutory and constitutional rights. (Pl.’s Mot. 11-12.)
Ryan accordingly seeks a preliminary injunction against Defendant Lizama and DRT officials, all
in their official capacities, that
(1) forbids the settlement, compromise, or resolution of his qui tam claim against Permarch
“without first giving [him] written notice and a meaningful opportunity to respond” (id. at
30);
(2) requires the submission of any proposed settlement of his qui tam claim against Permarch
to the Superior Court of Guam in his qui tam action against Permarch for approval and
forbids the execution, acceptance, or effectuation of any such settlement without judicial
approval (id.); and
(3) forbids the distribution, transfer, or any application of any proceeds collected from
Permarch “in a manner that defeats [Plaintiff’s] statutory share, attorneys’ fees, costs, and
expenses,” pending approval by the Superior Court of Guam in his qui tam action against
Permarch (id.).
II. LEGAL STANDARD
An injunction is an “extraordinary remedy” that does not “issue[] as of course” or to
“restrain an act the injurious consequences of which are merely trifling.” Weinberger v. Romero-
Barcelo, 456 U.S. 305, 311-12 (1982) (internal quotation marks omitted); see also id. at 313 (“The
grant of jurisdiction to ensure compliance with a statute hardly suggests an absolute duty to do so
under any and all circumstances, and a federal judge sitting as chancellor is not mechanically
obligated to grant an injunction for every violation of law.”). The Ninth Circuit has explained:
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A preliminary injunction can take two forms. A prohibitory
injunction prohibits a party from taking action and “preserve[s] the
status quo pending a determination of the action on the merits.”
Chalk v. U.S. Dist. Court, 840 F.2d 701, 704 (9th Cir. 1988); see also
Heckler v. Lopez, [463 U.S. 1328, 1333 (1983)] (a prohibitory
injunction “freezes the positions of the partiers until the court can
hear the case on the merits”). A mandatory injunction “orders a
responsible party to ‘take action.’” Meghrig v. KFC W., Inc.,, [516
U.S. 479, 484 (1996)]. A mandatory injunction “‘goes well beyond
simply maintaining the status quo [p]endente lite [and] is
particularly disfavored.’” Anderson v. United States, 612 F.2d 1112,
1114 (9th Cir. 1980) (quoting Martinez v. Mathews, 544 F.2d 1233,
1243 (5th Cir. 1976)). In general, mandatory injunctions “are not
granted unless extreme or very serious damage will result and are
not issued in doubtful cases or where the injury complained of is
capable of compensation in damages.” Id. at 1115 (quoting Clune v.
Publishers’ Ass’n of N.Y. City, 214 F. Supp. 520, 531 (S.D.N.Y.
1963)).
The status quo ante litem referenced in Chalk means “‘the last,
uncontested status which preceded the pending controversy.’”
Regents of the Univ. of Cal. v. Am. Broad. Cos., 747 F.2d 511, 514
(9th Cir. 1984) (quoting Tanner Motor Livery, Ltd. v. Avis, Inc., 316
F.2d 804, 809 (9th Cir. 1963)).
Marlyn Nutraceuticals, Inc. v. Mucos Pharma GmbH & Co., 571 F.3d 873, 878-79 (9th Cir. 2009).
“A plaintiff seeking a preliminary injunction must establish [1] that he is likely to succeed
on the merits, [2] that he is likely to suffer irreparable harm in the absence of preliminary relief,
[3] that the balance of equities tips in his favor, and [4] that an injunction is in the public interest.”
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). “Where, as here, the government
opposes a preliminary injunction, the third and fourth [Winter] factors merge into one inquiry.”1
Porretti v. Dzurenda, 11 F.4th 1037, 1047 (9th Cir. 2021). A prohibitory injunction can issue where
there exist “‘serious questions going to the merits’ and a balance of hardships that tips sharply
1 DRT is not named as a party in this suit. However, Ryan directs his request for an injunction against
Lizama in her official capacity as DRT Director; and Lizama’s opposition is couched as being made on
behalf of DRT. See also Porretti v. Dzurenda, 11 F.4th 1037, 1043 & n.1, 1047 (9th Cir. 2021) (applying
merging of third and fourth Winter factors in preliminary injunction analysis, even though named
defendants were individual prison officials and did not include any governmental entity).
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towards the plaintiff . . . , so long as the plaintiff also shows that there is a likelihood of irreparable
injury and that the injunction is in this public interest.” All. for the Wild Rockies v. Cottrell, 632
F.3d 1127, 1135 (9th Cir. 2011); cf. also Weinberger, 456 U.S. at 312 (“The Court has repeatedly
held that the basis for injunctive relief in the federal courts has always been irreparable injury and
the inadequacy of legal remedies.”). On the other hand, a plaintiff seeking a mandatory injunction
bears a “doubly demanding” burden as to the first Winter factor: “[he] must establish that the law
and facts clearly favor [his] position, not simply that [he] is likely to succeed.” Garcia v. Google,
Inc., 786 F.3d 733, 740 (9th Cir. 2015).
In exercising its “sound discretion” in issuing or withholding injunctive relief, Weinberger,
456 U.S. at 312, a district court may consider otherwise inadmissible evidence, see Flathead-Lolo-
Bitterroot Citizen Task Force v. Montana, 98 F.4th 1180, 1198 (9th Cir. 2024), and generally “must
consider all four Winter factors,” Baird v. Bonta, 81 F.4th 1036, 1040 (9th Cir. 2023) (internal
quotation marks omitted). But as the first factor “is a threshold inquiry and is the most important
factor,” should a plaintiff “fail[] to show a likelihood of success on the merits,” a district court
“need not consider the other factors[.]” Id. (internal quotation marks and citations omitted).
III. DISCUSSION
DRT contends Ryan cannot satisfy any of the four-part Winter standard. (DRT’s Resp. 5.)
In particular, DRT contends (1) Ryan cannot establish a likelihood of success on the proposition
that 5 GCA § 37103 and § 37203(e) give him the right to participate in DRT’s administrative
proceedings or tax negotiations; (2) he cannot establish irreparable injury because his exclusive
remedy is a statutory monetary award for which Guam law adequately provides a legal remedy;
(3) the balance of equities does not favor him because his right to an award is protected by law;
and (4) it is not in the public interest “for a relator to ask this Court to judicially force is [sic]
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presence into a non-party’s tax case that is pending before the Superior Court of Guam over the
application of purely local Guam business tax laws.” (Id. at 5-6.).
The Court declines to issue an injunction not on the grounds raised by DRT, but instead on
the ground that Ryan lacks standing to seek his requested preliminary injunctive relief because the
injuries Ryan claims are not sufficiently actual or imminent. As such, denial without prejudice of
his Motion is appropriate.
As with any other claim for relief, Ryan must satisfy the “irreducible constitutional
minimum of standing” necessary to invoke the Court’s subject-matter jurisdiction to issue his
desired preliminary injunctive relief. Lopez v. Candaele, 630 F.3d 775, 785 (9th Cir. 2010)
(quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992)). Such standing consists of three
elements: (1) injury in fact, i.e., “an invasion of a legally protected interest which is (a) concrete
and particularized” and “(b) actual or imminent, not conjectural or hypothetical”; (2) a “causal
connection between the injury and the conduct complained of”; and (3) a likelihood, rising above
mere speculation, that “the injury will be redressed by a favorable decision.” Lujan, 504 U.S. at
560-61 (internal quotation marks and citations omitted)). “[A]t the preliminary injunction stage,
a plaintiff must make a ‘clear showing’ of his injury in fact.” Lopez, 630 F.3d at 785 (citing Winter,
555 U.S. at 22).
Here, Ryan’s requested injunction is wholly conditional: the terms of the injunction
provide that DRT is not required to perform unless DRT (1) “settle[s], compromise[s], or otherwise
resolve[s]” the claim underlying Ryan’s qui tam action against Permarch, (2) arrives at a “proposed
settlement or proposal of settlement” of such claim, or (3) “collect[s]” “any proceeds . . . from
Permarch[.]” (Pl.’s Mot. 30.) Thus, at a minimum, Ryan must make out a showing that DRT is
indeed engaged in conduct to settle, compromise, or otherwise resolve the claim underlying his
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qui tam action against Permarch such that his claimed injury—namely, deprivation of his protected
property interest in the proceeds to be collected from Permarch—is actual and imminent.
At this juncture, first, as to any injury Ryan would suffer as a consequence of Permarch’s
now-pending appeal of DRT’s alleged re-determination of Permarch’s tax liability, the Court does
not discern any actual or imminent injury that Ryan faces in view of Ryan’s successfully moving
to intervene in the Tax Appeal Case. At bottom, Ryan’s claimed injury stems from the denial of
his right to notice and an opportunity to be heard on the merits of the amount of Permarch’s tax
liability—as the final determination on the total amount of proceeds to be collected from Permarch
also sets the amount of proceeds to which Ryan is entitled under the Whistleblower Act. See 5
GCA § 37103(b)(7) (“If the government of Guam elects not to proceed with [the qui tam action],
the Tax Enforcement Division shall award not less than thirty percent (30%) of the collected
proceeds (including penalties, interest, additions to tax, and additional amounts) resulting from the
action (including any related actions) or from any settlement in response to such action.”).2 Ryan’s
2 The Court rejects Defendant Lizama’s contention that Permarch’s tax appeal is not an “alternate remedy”
within the meaning of 5 GCA § 37203(e). Defendant Lizama does not dispute Ryan’s representations that
Permarch pursued the tax appeal after DRT had already made an initial assessment of Permarch’s tax
liability, assigned Ryan the right to prosecute the qui tam action against Permarch by electing not to
intervene in the action, and then re-assessed Permarch’s tax liability and triggered a new appeal period.
Thus, DRT’s own conduct created the conditions for the tax appeal—and any final judgment on the merits
in the tax appeal will conclusively determine the amount of Permarch’s tax liability not only in the tax
appeal, but also for the purposes of Ryan’s qui tam action and statutory entitlement to a cut of the proceeds.
See 5 GCA § 37203(e) (“Any finding of fact or conclusion of law made in such [alternate remedy]
proceeding that has become final shall be conclusive on all parties to [a qui tam action].”).
In other words, to borrow from the Ninth Circuit’s interpretation of the federal Whistleblower Act’s
“alternate remedy” language at 31 U.S.C. § 3730(c)(5), which language is substantively identical to 5 GCA
§ 37203(e), by re-determining Permarch’s tax liability and defending such re-determination in Permarch’s
tax appeal, DRT is “seek[ing] a remedy in such proceeding that effectively takes the place of the
[Whistleblower Act] remedy.” United States ex rel. Barajas v. United States, 258 F.3d 1004, 1011 (9th Cir.
2001); see also id. at 1012 (“It would be inconsistent not only with the plain meaning of the broad language
employed in the statute, but also with the purpose of the statute, to allow the government to obtain from a
qui tam defendant a remedy that could have been obtained in an already-filed [qui tam] action, and then to
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successful intervention in the Tax Appeal Case provides him with access to notice and a
meaningful opportunity to advance his interests concerning the re-determined amount of
Permarch’s tax liability before a neutral decisionmaker and, if necessary, to pursue or defend his
interests in any further appellate proceedings after entry of judgment in the Superior Court of
Guam.3 As such, any adverse decision on the re-determined amount of Permarch’s tax liability as
a result of the Tax Appeal Case being fully litigated does not implicate an actual or imminent injury
conferring standing for a preliminary injunction because Ryan will not have been, or is not likely
to be, deprived of his right to the proceeds without constitutionally sufficient due process.
Second, as to any injury Ryan would suffer should DRT settle Permarch’s tax liability
through any out-of-court methods, including any efforts to resolve Permarch’s tax appeal short of
full-blown litigation and judgment on the merits, Ryan only points to past conduct and associated
claimed injuries without identifying facts that indicate that DRT and Permarch are presently
engaged in out-of-court conduct that will imminently settle, compromise, or otherwise resolve the
claim underlying his qui tam action against Permarch. The Court is mindful that “[p]ast wrongs
. . . are ‘evidence bearing on whether there is a real and immediate threat of repeated injury.’”
Davidson v. Kimberly-Clark Corp., 889 F.3d 956, 967 (9th Cir. 2018) (quoting City of Los Angeles
v. Lyons, 461 U.S. 95, 102 (1983)). But past wrongs, standing alone, are insufficient to confer
standing; Ryan must instead show “a sufficient likelihood that he will again be wronged in a similar
way.” Id. (quoting Lyons, 461 U.S. at 102). “In other words, the ‘threatened injury must be
certainly impending to constitute injury in fact’ and ‘allegations of possible future injury are not
argue that the proceeds of that remedy need not be shared with the whistleblower because the remedy was
not an ‘alternate remedy’ within the meaning of the [Whistleblower Act].”).
3 The Parties dispute whether the Whistleblower Act confers Ryan with rights beyond his right to the
proceeds. The Court need not, and accordingly declines to, resolve the Parties’ dispute at this juncture.
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sufficient.’” Id. at 967 (quoting Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013)). On this
record, especially in view of Permarch’s filing its appeal of DRT’s re-determination of the former’s
tax liability and Ryan’s successful intervention in the tax appeal and without further information
concerning (at the very least) DRT and Permarch’s interactions, the Court cannot find that DRT is
imminently likely to engage in conduct that will almost certainly consummate a settlement in a
fashion akin to DRT’s interactions with Titan and Carson. Thus, as with any injury arising from
Permarch’s tax appeal, the Court similarly must conclude that Ryan is not facing actual or
imminent concrete injury arising from any possible out-of-court settlement between DRT and
Permarch. See also Trump v. California, Nos. 26A124 & 26A139, 609 U.S. ____, 2026 WL
2473573, at *2 (Aug. 24, 2026) (finding states lacked standing in suit against federal government
seeking to enjoin executive order concerning election integrity where to reach states’ claimed
injury, a court would be required to speculate not only on whether a government official will act,
but also “the shape that any such action might ultimately take,” and citing Clapper, 568 U.S. at
414-15 n.5, in explaining that “Article III prohibits federal courts from stacking hypothetical on
hypothetical to speculate that harm will eventually materialize”).
Third, Ryan’s claimed injury arising from any settlement between DRT and Permarch that
would purport to compromise Ryan’s claim to attorneys’ fees, costs, and expenses under the
Whistleblower Act cannot confer standing because the Whistleblower Act appears to vest the
determination of such fees, costs, and expenses exclusively in the court hearing Ryan’s qui tam
action—i.e., any “alternate remedy” cannot compromise Ryan’s right to fees, costs, and expenses.
Under 5 GCA § 37203(e), Ryan is entitled to “the same rights” in any alternate remedy proceeding
“as [he] would have had if the [qui tam] action had continued under [5 GCA § 37203].” Regardless
of whether the Government of Guam elects to intervene in his qui tam action, should Ryan
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prevail—whether on the action directly or through settlement resulting from the action—Ryan is
entitled to “receive an amount for reasonable expenses which the court finds to have been
necessarily incurred, plus reasonable attorneys’ fees and costs. All such expenses, fees, and costs
shall be awarded against the defendant.”4 5 GCA § 37204(a) (emphasis added) (Government of
Guam elects to intervene); id. § 37204(b)(2) (emphasis added) (Government of Guam declines to
intervene and plaintiff prevails on the action or settles the action); 5 GCA § 37103(b)(7) (emphasis
added) (Government of Guam declines to intervene and obtains a settlement in response to qui tam
action). Thus, absent a clear showing that any potential settlement between DRT and Permarch
would preclude Ryan from pursuing his statutorily authorized fees, costs, and expenses through
the ordinary course of litigation in his qui tam action, Ryan’s claim of injury as to this aspect of
his possible recovery is also too speculative to confer standing.
IV. CONCLUSION
The Court is constrained to conclude that Ryan is not facing actual or imminent concrete
injury that is sufficient to confer him with standing to seek his requested preliminary injunction
against the DRT Director. The Court emphasizes, however, that this order does not conclusively
resolve the arguments on the merits the Parties raise or the scope of Ryan’s rights under the
Whistleblower Act. Accordingly, the Court DENIES WITHOUT PREJUDICE Ryan’s Motion for
a Preliminary Injunction (ECF No. 108).
4 As any expenses, fees, and costs would be awarded against the qui tam defendant, it appears that a qui
tam defendant engaged with DRT to pursue any “alternate remedy” would be well advised to also notify
the qui tam relator of the developments in those proceedings regardless of whether DRT discharges its due
process obligations to the qui tam relator. Should DRT and a qui tam defendant settle the claim without
notifying the qui tam relator, nothing precludes the qui tam relator from arguing that the continued
prosecution of the qui tam action after the settlement was reasonable such that the qui tam defendant should
compensate the qui tam relator for all expenses, fees, and costs incurred while the qui tam relator was left
out of the loop—especially if DRT and the qui tam defendant sought to conceal the fact of settlement from
the qui tam relator.
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IT IS SO ORDERED this 13th day of October, 2026.
____________________________________
RAMONA V. MANGLONA
District Judge
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