The 4th US Circuit Court of Appeals declined to issue an injunction in a case involving Joe Manis, who was accused of entering a “sore” Tennessee Walking Horse into a competition, violating the Horse Protection Act (HPA). Manis challenged the administrative proceedings on constitutional grounds, alleging violations related to the Appointments Clause, removal protections of USDA administrative law judges (ALJs), the right to a jury trial, and Article III requirements. However, both the district court and the appellate court found that Manis failed to demonstrate irreparable harm necessary for injunctive relief, despite ongoing administrative penalties including a fine and a one-year ban from horse events.

The appellate judges rejected Manis’s reliance on the 2023 Axon Enterprise Inc. v. FTC precedent, clarifying that while Axon allows federal court challenges to allegedly unconstitutional agency proceedings, it does not mandate halting such proceedings automatically. The court emphasized that constitutional claims alone do not establish irreparable harm sufficient to justify preliminary injunctions, and thus refused to stop the administrative process against Manis.