Franklin Leroy Stephens v. Hazel Colley

Summary

The court reversed and remanded a preliminary injunction because the circuit court's order did not state the reasons for issuing it, as required by Rule 65(d)(2). Because that defect was dispositive, the court did not decide whether the evidence supported the injunction under the applicable four-part test. Justice Shaw, concurring in the result, reasoned that incorporating reasons from another document might satisfy the rule but joined the result because existing precedent required reversal.