Marketing Displays International v. Shaw, No. 23-1028 (6th Cir. 2024)
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In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Marketing Displays International (MDI), sued the defendant, Brianna Shaw, for allegedly violating her one-year non-compete agreement when she left MDI and began working for another company. The district court granted a preliminary injunction, preventing Shaw from working for her new employer for one year. Shaw appealed this decision in January 2023. However, due to several deadline extensions requested by both parties, the briefing did not finish until January 2024. By that time, the one-year period of the injunction had already expired, rendering the appeal moot.
Shaw argued that the appeal was not moot as a ruling would impact her ability to recover any damages, including reputational harm caused by the injunction, and MDI's ability to recover attorney fees. The court disagreed, stating that Shaw could not collect damages until a final judgment is in her favor, and MDI's right to attorney fees did not depend on the validity of the preliminary injunction.
Shaw also requested the court to vacate the moot portion of the preliminary injunction. However, the court refused, stating that the injunction would not have any preclusive effect on future litigation and that Shaw contributed to the appeal's mootness by requesting deadline extensions.
Therefore, the appeal was dismissed as moot, and the case was remanded back to the lower court for further proceedings.
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