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The United States Supreme Court reiterated the four-part standard for injunctive relief it announced in 2008, confirming that this same standard applies in cases arising under NEPA. In a 7-1 opinion delivered by Justice Alito in Monsanto Co. v. Geertson Seed Farms (Monsanto), the Court relied on its earlier opinions in Winter v. Natural Resources Defense Council, and eBay Inc. v. MercExchange, L.L.C., holding that showings of:

1) irreparable injury,

2) inadequacy of legal remedies,

3) a balance of hardships tipping in favor of the party seeking the injunction and

4) consideration of the public interest

are all necessary before an injunction may issue.

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