Was the District Court Required to Enter the Narrowly Tailored Injunction?
In arguing that the lower courts abused their discretion, Monsanto points to the availability of less-intrusive measures that would have “eliminated any conceivable risk of harm.” See Brief for Petitioners at 47. Relying on a number of Supreme Court cases, Monsanto argues that district courts are required to narrowly tailor injunctions in order to make them no more burdensome to the defendant than necessary. See id. at 47-48. APHIS had proposed a narrowly tailored injunction that would have established stewardship measures, including safe-distances between crops. See id. at 48. Monsanto argues that in refusing to seriously consider the efficacy of APHIS’ proposed measure in preventing irreparable harm, the district court abused its discretion and issued a blanket injunction that was more burdensome to Monsanto than necessary. See id. Relying on scientific evidence, Monsanto supports its argument that the injunction proposed by APHIS would have been effective in preventing irreparable h
