The opinion
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
LISA SHARON BURCHFIELD, )
)
Plaintiff, )
)
v. ) No. 4:25-cv-00847-MTS
)
CITY OF BERKELEY POLICE )
DEPARTMENT, et al., )
)
Defendants. )
MEMORANDUM AND ORDER
Plaintiff Lisa Sharon Burchfield, a self-represented litigant, moves for a temporary
restraining order and preliminary injunction. Doc. [7]. Under Federal Rule of Civil
Procedure 65, such relief is an extraordinary remedy, appropriate only upon a clear
showing of irreparable harm. See Gen. Motors Corp. v. Harry Brown’s, LLC, 563 F.3d
312, 318–19 (8th Cir. 2009). Having reviewed the Motion and considered the proper
standard, the Court finds no basis for immediate injunctive relief. See Dataphase Sys., Inc.
v. C L Sys., Inc., 640 F.2d 109, 114 (8th Cir. 1981) (en banc) (listing factors to consider).
Even construing the Motion liberally, Burchfield fails to demonstrate a likelihood
of success on the merits or an immediate threat of irreparable harm. See id. Her motion
consists of broad and conclusory allegations of police harassment, unlawful ticketing in
2023, and an alleged assault by a Berkeley police officer in August 2025. Doc. [7] at 1–3.
These allegations concern past events and do not establish any immediate, non-speculative
threat of future irreparable injury. See H&R Block, Inc. v. Block, Inc., 58 F.4th 939, 951
(8th Cir. 2023).
Furthermore, Burchfield’s requested relief—including prohibiting any officer from
approaching or contacting her and imposing a 300-yard exclusion zone around her home,
vehicle, and workplace—is sweeping, unsupported by factual detail, and beyond the scope
of emergency relief available under Rule 65. Additionally, to the extent Burchfield seeks
to enjoin an upcoming municipal proceeding or obtain injunctive relief against a judicial
officer acting in a judicial capacity, such relief is unavailable as a matter of law. See 42
U.S.C. § 1983 (limiting injunctive relief against judicial officers); see also Night Clubs,
Inc. v. City of Fort Smith, 163 F.3d 475, 479-81 (8th Cir. 1998) (holding federal courts
may not interfere with ongoing state or municipal proceedings absent bad faith,
harassment, or other extraordinary circumstances (applying Younger v. Harris, 401 U.S.
37 (1971))).
Because Burchfield has not shown circumstances warranting emergency or
preliminary relief, the Court will deny her Motion. The Court will address Burchfield’s
Complaint and Motion to Proceed in Forma Pauperis in the ordinary course.
Accordingly,
IT IS HEREBY ORDERED that Burchfield’s Motion for Temporary Restraining
Order and Preliminary Injunction, Doc. [7], is DENIED.
Dated this 9th day of December 2025. |)
fA
UNITED STATES DISTRICT JUDGE