Grupo Mexicano De Desarrollo, S. A. v. Alliance Bond Fund, Inc.

Summary

The Supreme Court held that a federal district court lacks the power, in an action for money damages, to issue a preliminary injunction freezing a defendant's assets when the plaintiff claims no lien or equitable interest in them, because such pre-judgment relief was historically unavailable from courts of equity and any expansion of traditional equitable remedies is for Congress. It also held that the interlocutory appeal was not mooted by the intervening permanent injunction, since petitioners retained a potential wrongful-injunction claim on the injunction bond under Rules 65(c) and 65.1 that is independent of the merits. The Court accordingly reversed the Second Circuit's affirmance of the preliminary injunction. Justice Ginsburg, concurring in part and dissenting in part, joined by Justices Stevens, Souter, and Breyer, would have affirmed, treating the freeze order as a modest, status quo-preserving exercise of flexible federal equity power.