Sixth Circuit Affirms Denial of Preliminary Injunction, Holding That Termination of Disability and Life-Insurance Benefits Does Not Constitute Irreparable Harm

In Tascarella v. Aptiv US General Services Partnership, No. 26-3101, 2026 WL 2243787 (6th Cir. Aug. 4, 2026), the Sixth Circuit affirmed the denial of a preliminary injunction sought by an employee attempting to prevent his employer from terminating his employment and interfering with his employment benefits. Plaintiff accepted a position as a plant manager and began work in late September 2025, attracted in part by what he understood to be immediate vesting of employment benefits. After his second day, Plaintiff experienced severe medical symptoms and was hospitalized; his physician diagnosed liver cirrhosis, portal hypertension, hepatic encephalopathy, and stage-four liver failure, and recommended placement on a liver-transplant list. An administrator approved short-term disability benefits from October 1, 2025 to April 7, 2026. After Plaintiff advised the employer he would need to extend his leave indefinitely, the employer announced its intention to terminate his employment, citing the critical nature of the plant-manager position and the burden of leaving it vacant. Plaintiff sued in Ohio state court, asserting six claims, including ERISA interference under Section 510, and moved for a temporary restraining order and preliminary injunction. After removal, the district court denied the preliminary-injunction motion, finding Plaintiff had not met his burden on any of the four factors.

The Court of Appeals reviewed the law de novo, the facts for clear error, and the remedial decision for abuse of discretion. It acknowledged that the district court erred by requiring Plaintiff to prove his case by clear and convincing evidence, but affirmed on an alternative ground supported by the record: Plaintiff failed to demonstrate irreparable harm, a factor the court described as indispensable. Harm is irreparable, the court explained, only if it is not fully compensable by monetary damages and is both certain and immediate rather than speculative or theoretical.

The court held that the harm Plaintiff alleged, termination of his employment and employment benefits, is quintessentially reparable by money damages. Salaries, short-and long-term disability benefits, life-insurance payments, and retirement benefits are all denominated in terms of money, and denied or withdrawn health-insurance coverage is ultimately monetary in nature and generally remediable with damages. The court addressed Plaintiff’s argument that termination of his long-term disability benefits and life-insurance policy might render him permanently ineligible for reinstatement of that coverage. Even assuming those scenarios presented sufficiently certain harm, the court reasoned, they are compensable with money damages: should Plaintiff or his estate succeed on the merits, the district court could award damages in the full amount of what he would have received under the terminated disability and life-insurance policies.

The court distinguished its unpublished decisions in Welch v. Brown and Izquierdo v. Wipro Ltd., in which loss of health insurance supported a finding of irreparable harm. Those cases turned on a critical need for healthcare coupled with a financial barrier to obtaining coverage or care. Here, the district court found Plaintiff eligible for Medicare, Social Security, and COBRA continuation of his employer health-insurance coverage, and found he had not pled a financial barrier to obtaining the coverage or healthcare he needed. Plaintiff’s sworn assertion that he and his wife would suffer great undue hardship and be at great risk of being unable to obtain needed medical treatment was, in the court’s view, at best unspecific, unsupported, and theoretical speculation, and at worst a legal conclusion masquerading as a factual allegation. The court likewise found no clear error in the district court’s treatment of the alleged harm to Plaintiff’s wife, who was eligible for COBRA continuation and had become Medicare-eligible after the district court’s ruling.

Concluding that Plaintiff might ultimately prevail on the merits but had not shown the irreparable harm required for interim relief, the Sixth Circuit affirmed the denial of the preliminary injunction and denied as moot the employer’s motion to strike Plaintiff’s reply brief.