Emotional Distress Alone Is Not Irreparable Harm, and Asset Freezes Are Limited: A Commentary on Shangrila Partnership v. Lemos

I. Introduction

A. The Dispute in Context

This case arises from a deeply personal and contentious family conflict international in scope. Plaintiff–appellant Silvia Lazo, together with Shangrila Partnership, sued a number of defendants including her sister, Helena Maria Lemos, in the Western District of Michigan. The broader complaint alleges intentional infliction of emotional distress (IIED), tortious interference, civil conspiracy, civil extortion, civil intimidation, and racketeering, all essentially grounded in the assertion that Lemos and others are isolating the sisters’ mother, Sonia Mannelli (living in Brazil), to gain control of her assets.

The appeal to the Sixth Circuit, however, is narrow. It concerns only:

• Lazo’s claim of intentional infliction of emotional distress against Lemos; and
• Whether the district court erred in denying Lazo’s motion for preliminary injunctive relief.

More specifically, Lazo sought a preliminary injunction to:

• Restrict a wide range of Lemos’s alleged conduct toward both Lazo and their mother; and
• Impose a constructive trust over Lemos’s assets to secure any eventual money judgment.

The district court denied the preliminary injunction, finding that Lazo failed to demonstrate a likelihood of success on the merits and, crucially, failed to show irreparable harm. Lazo appealed. The Sixth Circuit (Judge McKeague writing, joined by Judges Griffin and Mathis) affirmed.

B. Central Issues on Appeal

The appellate opinion focuses on four core questions:

1. Did the district court abuse its discretion in concluding that Lazo failed to demonstrate irreparable harm, a prerequisite for preliminary injunctive relief?
2. Can emotional distress alone—even if severe—satisfy the irreparable harm requirement?
3. Did the district court have authority to impose a constructive trust / asset freeze over Lemos’s property simply to secure potential future money damages?
4. Did the district court procedurally err by failing to make adequate findings under Federal Rule of Civil Procedure 52(a) or by considering allegedly “non‑competent” evidence?

While formally “not recommended for publication,” the opinion is doctrinally significant in two respects:

• It reinforces, and articulates with unusual clarity, that emotional distress, standing alone, is not irreparable harm for purposes of a preliminary injunction.
• It reaffirms the strict limits on freezing a defendant’s assets in a purely damages action, applying Grupo Mexicano and traditional equity principles.

II. Summary of the Opinion

A. Holding

The Sixth Circuit affirmed the district court’s order denying Lazo’s motion for a preliminary injunction.

B. Key Conclusions

1. No irreparable harm shown as to Lemos’s conduct. Lazo offered almost no admissible or concrete evidence that Lemos had interfered—or was imminently likely to interfere—with Lazo’s visits to her mother, with Mannelli’s medical care, or with the safety of Lazo or Mannelli. Her fears were speculative, not “certain and immediate.”
2. Emotional distress damages are not irreparable harm. The injury alleged in the underlying IIED claim—emotional distress—can be compensated by money damages, which Lazo in fact seeks. Therefore it is not “irreparable” within the meaning of the preliminary injunction doctrine.
3. No authority to impose a prejudgment asset freeze / constructive trust on Lemos’s property. Because Lazo’s suit is for money damages and she asserts no present property interest or lien in Lemos’s assets, the district court lacked equitable power to sequester those assets in a trust merely to secure a potential future judgment, under Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc.
4. Procedural challenges rejected. The court held that:
   • The district court’s order complied with Rule 52(a); detailed narrative findings are not required so long as the reasoning is sufficient to permit appellate review.
   • Any alleged defects in translations or “noncompetent” evidence are immaterial, because both the district court and the Sixth Circuit resolved the preliminary injunction motion without relying on that contested material.

III. The Court’s Legal Reasoning

A. Scope of the Appeal

The appellate court carefully cabins the case. Although the district court action involves multiple defendants and complex issues (including parallel proceedings in Brazil over guardianship for the mother), the appeal addresses only:

• Lazo’s IIED claim against Lemos, and
• Whether Lazo is entitled to preliminary injunctive relief on that claim.

This focus is important: Lazo attempted to frame many of her factual assertions as harm to her mother, but the court underscores that its equitable analysis is fundamentally about Lazo’s own alleged injury, not the mother’s welfare in the abstract—especially given that the mother is a nonparty, and that U.S. courts’ equitable power is generally party‑specific.

B. Standard of Review and the Preliminary Injunction Framework

The court applies the usual abuse-of-discretion standard to review the denial of a preliminary injunction, citing NHL Players’ Ass’n v. Plymouth Whalers Hockey Club, 325 F.3d 712 (6th Cir. 2003), and McGirr v. Rehme, 891 F.3d 603 (6th Cir. 2018). A decision is reversible only if it:

• Relied on clearly erroneous factual findings;
• Improperly applied governing law; or
• Used an erroneous legal standard.

The substantive standard for preliminary injunctions is set out (citing Benisek v. Lamone, Winter v. NRDC, and D.T. v. Sumner County Schools, 942 F.3d 324 (6th Cir. 2019)):

1. Likelihood of success on the merits;
2. Likelihood of immediate, irreparable harm absent an injunction;
3. The balance of equities; and
4. The public interest.

Crucially, following D.T., the court stresses:

Even a strong showing on the other three factors does not dispense with the irreparable harm requirement. A district court is “well within its province” to deny a preliminary injunction solely because the plaintiff has not established imminent, non-speculative irreparable harm.

C. No Evidence of Imminent Irreparable Harm from Lemos’s Conduct

Lazo’s requested injunction sought to bar Lemos from:

1. Interfering with Lazo’s visitation and care of their mother;
2. Creating unsafe conditions for Lazo or their mother;
3. Preventing medical care for their mother;
4. Hiding or disposing of any of the mother’s or plaintiffs’ assets; and
5. Hiding or disposing of their mother’s body if she should die.

The court dissects each request under the irreparable-harm standard.

1. Visitation and Care

Lazo’s central narrative: Lemos conspires with a Brazilian caretaker, Hamilton Praxedes, to keep Lazo away from their mother and to control the mother’s care and resources.

The evidence: Lazo identifies a December 6, 2024 incident where Praxedes refused her access to the property while allegedly on the phone with Lemos. She recorded and transcribed the call and placed it in the record.

The court’s assessment is blunt:

• Nothing in the recording or transcript identifies Lemos as a speaker.
• Nothing in the transcript can reasonably be read as Praxedes receiving instructions from Lemos to bar Lazo.
• Even accepting that Praxedes refused entry once, the causal link to Lemos is missing.

Further, Lazo does not assert any future plans to visit her mother or explain why an interference is “certain and immediate” rather than hypothetical. Without a concrete, impending event and evidence Lemos will interfere, the harm is speculative.

2. Unsafe Conditions and Medical Care

Lazo alleges that:

• Her mother lives in an unsafe, dilapidated dwelling in Brazil; and
• Lemos and Praxedes are preventing adequate medical care (e.g., for dementia and breast cancer).

The record, by contrast, shows:

• The mother attends medical appointments but sometimes refuses treatment, such as wound dressing.
• Praxedes had recently repaired windows and repainted the interior, undercutting the “run-down shack” characterization.

Critically, the court finds no evidence that:

• Lemos caused any unsafe conditions; or
• Lemos prevented or is likely to prevent medical care.

At most, Lazo has a disagreement over the level and type of care her mother should receive. That does not constitute evidence of an imminent, irreparable injury attributable to Lemos, as required under Michigan Coalition of Radioactive Material Users v. Griepentrog, 945 F.2d 150 (6th Cir. 1991), and D.T.

3. Risk of Hiding Assets or the Mother’s Body

Lazo further speculates that Lemos is siphoning off their mother’s pension and Social Security benefits and might hide or dispose of assets—or even the mother’s body—if the mother dies.

The court notes:

• These allegations are made only “on information and belief,” with no supporting evidence in the record.
• There is no indication that the mother’s death is imminent.
• The relief requested is essentially a “contingency‑plan injunction” against a chain of hypothetical future events.

Under D.T. and Griepentrog, such “ifs” are precisely what do not qualify as irreparable harm: the injury must be “both certain and immediate,” not “speculative or theoretical.”

4. Party-Specific Equity and Relief Benefitting a Nonparty

The court references Trump v. CASA, Inc., 606 U.S. 831 (2025), to emphasize that “party‑specific principles permeate our understanding of equity” and that courts generally refuse to grant equitable relief to nonparties.

Much of the requested injunction would directly benefit the nonparty mother—for example, prohibiting Lemos from creating unsafe conditions for the mother or preventing her medical care. The opinion implicitly highlights a structural issue:

• Federal courts are not roving ombudsmen for nonparties’ welfare.
• Equitable power is aimed at providing complete relief to parties before the court, not policing third‑party conduct in general.

Although Lazo attempts to recast her mother’s alleged mistreatment as a vehicle for her own IIED claim, the court finds she still cannot demonstrate a non-speculative, imminent, irreparable injury to herself attributable to Lemos.

D. Emotional Distress Is Not Irreparable Harm

A central doctrinal point is the court’s treatment of emotional distress as a form of injury.

Lazo’s underlying cause of action against Lemos is intentional infliction of emotional distress. The traditional remedy for IIED is money damages for the plaintiff’s psychological and emotional suffering. The district court held—and the Sixth Circuit affirms—that such damages are not irreparable.

The Sixth Circuit reiterates that:

Lazo cited EEOC v. Chrysler Corp., 733 F.2d 1183 (6th Cir. 1984), arguing that emotional distress was treated there as an irreparable harm. The court rejects this reading:

• In Chrysler, the plaintiffs faced loss of work and future employment prospects, which are often deemed irreparable because they can permanently harm a plaintiff’s career trajectory and business standing.
• Emotional distress was merely one among several harms the Court considered; it was not the sole basis for the irreparable harm finding.

To reinforce this, the court cites Hall v. Edgewood Partners Ins. Ctr., Inc., 878 F.3d 524 (6th Cir. 2017), recognizing that harm to a competitive business position—not mere pain and suffering—can be irreparable.

The opinion then states a clear doctrinal proposition:

This is the key legal takeaway: in the Sixth Circuit, emotional distress by itself is not enough to justify a preliminary injunction. That principle has implications far beyond family disputes, including employment, civil rights, and defamation cases, where plaintiffs often allege substantial emotional injury.

E. No Authority to Freeze Lemos’s Assets via Constructive Trust

The second major component of Lazo’s motion was a request that the court impose a constructive trust over Lemos’s personal and community property interests. Lazo feared that Lemos’s divorce proceedings might dissipate those assets and render her “judgment‑proof” if Lazo prevailed in the lawsuit.

The Sixth Circuit rejects this request on two independent grounds:

1. Failure of proof. Lazo offered no evidence that the divorce proceedings would in fact hinder Lemos’s ability to satisfy a potential judgment.
2. Lack of equitable authority. Under Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999), the district court lacked power to sequester Lemos’s assets in advance of any judgment in an action seeking purely legal relief (money damages), in which the plaintiff asserts no present property interest or lien in those assets.

The court’s application of Grupo Mexicano is straightforward:

• Lazo’s lawsuit is a tort action seeking damages.
• She does not assert an existing equitable claim to Lemos’s specific property (e.g., as a beneficiary, constructive owner, or lienholder).
• Thus, under Grupo Mexicano and its reliance on De Beers Consol. Mines v. United States, 325 U.S. 212 (1945), the district court could not issue an injunction to “sequestrate” Lemos’s assets simply to preserve them for a future money judgment.

As the Supreme Court warned in Grupo Mexicano, allowing such prejudgment asset freezes in purely damages cases would:

The Sixth Circuit adopts that concern and holds that the district court “rightfully refused” the request. In short, constructive trusts and asset freezes remain tightly cabined to cases where the plaintiff has a present equitable interest in the property or where specific statutes expand equitable remedies. They are not available merely as a hedge against the risk of non-collection in ordinary tort cases.

F. Procedural Challenges: Rule 52(a) and Evidence Competency

1. Rule 52(a) Findings and Conclusions

Lazo argued that the district court failed to comply with Federal Rule of Civil Procedure 52(a), which requires a court deciding a preliminary injunction to:

• “State the findings and conclusions that support its action.”

The Sixth Circuit, citing Six Clinics Holding Corp., II v. Cafcomp Systems, Inc., 119 F.3d 393 (6th Cir. 1997), emphasizes that Rule 52(a) is:

The rule does not require a lengthy narrative of the full factual and procedural background. It requires only enough detail to permit meaningful appellate review.

The Sixth Circuit concludes that the district court’s order:

• Sufficiently outlined the underlying facts;
• Explained its rationale regarding irreparable harm and likelihood of success; and
• Gave the appellate court a “full understanding of the issues.”

Accordingly, there was no procedural error under Rule 52(a), and no remand was necessary.

2. Uncertified Translations and “Noncompetent” Evidence

Lazo also attacked the district court’s consideration of certain evidence—specifically, uncertified translations from Portuguese—as “noncompetent.”

The Sixth Circuit sidesteps the evidentiary dispute by observing that:

• The district court found Lazo failed to present sufficient evidence to justify a preliminary injunction without relying on these translations;
• The court of appeals likewise resolves the case solely on the basis of Lazo’s own submissions, without relying on the challenged evidence.

On that basis, the court finds no error and explicitly declines to decide whether those materials were properly considered.

IV. Precedents and Doctrinal Foundations

A. Irreparable Harm and Preliminary Injunction Structure

• Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) and Benisek v. Lamone, 585 U.S. 155 (2018):
  These Supreme Court cases articulate the modern framework for preliminary injunctions and emphasize that such relief is an “extraordinary remedy” never awarded as of right.
• D.T. v. Sumner County Schools, 942 F.3d 324 (6th Cir. 2019):
  Heavily relied upon for the proposition that the irreparable-harm factor is “indispensable,” and that a “hypothetical threat” cannot justify a preliminary injunction. The court specifically adopts the formulations that harm must be “certain and immediate,” not “speculative or theoretical.”
• Michigan Coalition of Radioactive Material Users, Inc. v. Griepentrog, 945 F.2d 150 (6th Cir. 1991):
  Provides the canonical language that a plaintiff “must provide some evidence that the harm has occurred in the past and is likely to occur again,” and that the injury must be “certain and immediate.” The court uses Griepentrog to frame the insufficiency of Lazo’s speculative fears.
• Overstreet v. Lexington-Fayette Urban County Gov’t, 305 F.3d 566 (6th Cir. 2002):
  Defines “irreparable harm” as an injury “not fully compensable by monetary damages.” The court adopts this definition to classify emotional distress damages as reparable.
• EOG Res., Inc. v. Lucky Land Mgmt., LLC, 134 F.4th 868 (6th Cir. 2025):
  Post-dating the knowledge cutoff but quoted in the opinion for two propositions:
  • “Irreparable harm is the core of the preliminary injunction.”
  • “Not every injury is irreparable.”
  The Sixth Circuit uses it to reiterate that purely economic damages or injuries reparable by money do not suffice.
• Memphis A. Philip Randolph Inst. v. Hargett, 2 F.4th 548 (6th Cir. 2021) and ACLU Fund of Michigan v. Livingston County, 796 F.3d 636 (6th Cir. 2015):
  Cited for the basic allocation of burdens: the party seeking a preliminary injunction bears the burden of justifying such relief.

B. Emotional Distress and Irreparable Harm

• EEOC v. Chrysler Corp., 733 F.2d 1183 (6th Cir. 1984):
  Lazo invoked this case to argue that emotional distress can be irreparable harm. The court responds by distinguishing it: Chrysler primarily involved loss of work and future employment prospects—harms that cannot be easily remedied by damages because they can permanently reshape a plaintiff’s career. Emotional distress was part of the harm, but not the irreparable component standing alone.
• Hall v. Edgewood Partners Ins. Ctr., Inc., 878 F.3d 524 (6th Cir. 2017):
  Support for the idea that certain intangible injuries—like harm to a competitive business position—may qualify as irreparable because they cannot be fully remedied by post hoc damages.

When read together with Shangrila Partnership v. Lemos, these precedents establish a clear line:

• Economic and market-based injuries that alter competitive or career status can be irreparable.
• Pure emotional distress, without such additional consequences, is not irreparable.

C. Equitable Limits on Asset Freezes: Grupo Mexicano and De Beers

• Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999):
  A foundational Supreme Court decision holding that, in an action seeking money damages where the plaintiff has no lien or equitable claim to specific property, a district court lacks the authority to issue a preliminary injunction freezing the defendant’s assets to secure a potential future judgment.
• De Beers Consolidated Mines v. United States, 325 U.S. 212 (1945):
  Earlier authority invoked in Grupo Mexicano to limit injunctions that would effectively place a defendant’s entire estate in judicial custody before any liability is established.

The Sixth Circuit straightforwardly applies these cases to hold that:

• Lazo’s fear that Lemos may become judgment-proof does not justify a constructive trust;
• The court may not use equitable powers to guarantee the collectability of a purely legal judgment.

D. Party-Specific Equity: Trump v. CASA, Inc.

Trump v. CASA, Inc., 606 U.S. 831 (2025), is cited (as quoted in the opinion) for the proposition that:

• Equitable remedies are generally party-specific; courts typically refuse to grant relief to nonparties.

This idea supports the court’s reluctance to grant expansive injunctive relief focused on protecting the nonparty mother’s interests under the guise of Lazo’s IIED claim. While the opinion does not turn solely on this principle, it reinforces the gravitational center of federal equity: remedy the injuries of those properly before the court, not restructure the lives of third parties.

E. Standard of Review and Appellate Practice

• NHL Players’ Ass’n v. Plymouth Whalers Hockey Club, 325 F.3d 712 (6th Cir. 2003), McGirr v. Rehme, 891 F.3d 603 (6th Cir. 2018), Hunter v. Hamilton County Board of Elections, 635 F.3d 219 (6th Cir. 2011):
  These cases supply the abuse-of-discretion lens and show that appellate courts may affirm on any ground supported by the record.
• Int’l Union of Painters & Allied Trades Dist. Council No. 6 v. Smith, 148 F.4th 365 (6th Cir. 2025):
  Quoted for the proposition that a denial of injunctive relief can be affirmed “for any reason supported by the record.”
• Six Clinics Holding Corp., II v. Cafcomp Systems, Inc., 119 F.3d 393 (6th Cir. 1997):
  Clarifies the purpose and scope of Rule 52(a) findings and conclusions.

V. Complex Concepts Simplified

A. Preliminary Injunction vs. Money Damages

A preliminary injunction is a court order issued early in a case to prevent harm before the trial is over. Because it is issued before liability is fully established, the bar is high: the movant must show that waiting for a normal judgment would cause harm that cannot later be fixed.

By contrast, a money judgment is awarded after the case is decided and compensates the plaintiff for harm already suffered. If money will be an adequate remedy later, courts will normally not issue a preliminary injunction now.

B. “Irreparable Harm” in Plain Terms

“Irreparable harm” means harm that cannot be fixed by money later. Examples might include:

• Loss of unique property or constitutional rights;
• Permanent damage to business goodwill or competitive position;
• Ongoing violations of rights where damages wouldn’t fully address the ongoing injury.

In this case, Lazo’s core alleged injury is emotional distress. Because courts can assign a dollar value to emotional harm and award damages if she wins, that injury is legally considered reparable.

C. Intentional Infliction of Emotional Distress (IIED)

IIED is a tort where the defendant:

• Engages in extreme and outrageous conduct;
• Intends to cause (or recklessly disregards the risk of causing) emotional distress; and
• Actually causes severe emotional distress.

Even if Lazo could eventually prove all these elements at trial, that would entitle her primarily to damages for her mental suffering. It does not, by itself, justify pre-trial equitable relief, especially without proof of imminent future injury.

D. Constructive Trust and Asset Freezes

A constructive trust is an equitable remedy where the court treats someone holding property as a “trustee” for the rightful beneficiary, usually because the property was obtained through fraud, breach of duty, or mistake. It is a way of restoring specific property to the person who ought to have it.

By contrast, Lazo asked for a constructive trust not because she presently owns or has any equitable right to Lemos’s assets, but to ensure those assets are available to satisfy a future money judgment. Under Grupo Mexicano, this is beyond the reach of equity in a standard damages action.

E. “Information and Belief” vs. Evidence

Pleadings often use the phrase “on information and belief” when a party suspects certain facts but lacks first-hand knowledge. This can be acceptable at the complaint stage.

However, when asking for a preliminary injunction, a party must go beyond belief and speculation and supply actual evidence—documents, affidavits, testimony, or other proof—showing that the alleged harm is real, has occurred, and is likely to recur imminently. Lazo failed to make that evidentiary showing.

F. Party-Specific Equity and Nonparties

Equity traditionally focuses on providing “complete relief” between the parties to a case. Expansive injunctions that primarily protect the rights of people who are not before the court (nonparties) are disfavored.

Here, many of Lazo’s requested injunctions—such as preventing unsafe conditions for her mother or curbing interference with the mother’s medical care—primarily address the mother’s welfare, not Lazo’s. The court emphasizes that it cannot simply oversee the life and medical care of a nonparty living abroad under the general heading of equitable relief.

VI. Impact and Future Implications

A. Clarifying Irreparable Harm in Emotional-Distress Cases

The opinion is especially important for litigants in tort, employment, civil rights, and defamation cases who seek immediate injunctive relief based on severe emotional injury.

By expressly stating that the Sixth Circuit has not held emotional distress alone sufficient to satisfy the irreparable harm requirement—and declining to do so here—the panel:

• Reinforces a clear boundary between compensable emotional harm and truly irreparable loss;
• Makes it significantly harder to obtain preliminary injunctions based solely on fears of future emotional suffering absent additional non-compensable injury.

B. Tightening the Use of Constructive Trusts and Asset Freezes

For plaintiffs and practitioners, the opinion underscores that:

• Prejudgment asset freezes in purely damages actions remain largely off the table in federal court;
• Concerns that a defendant may become judgment-proof, while understandable, do not by themselves justify an equitable seizure of property;
• Constructive trusts must be tied to present equitable interests in specific assets—not merely potential future damage awards.

This will influence litigation strategies in complex tort and commercial cases. Parties who fear asset dissipation will need to:

• Plead and prove equitable claims (e.g., restitution, constructive trust, fraudulent conveyance) with present property interests; or
• Rely on statutory mechanisms (where available) that explicitly authorize asset restraints.

C. Cross-Border Family Disputes and Federal Equitable Power

The opinion implicitly signals that federal courts will be cautious in stepping into highly personal, international family disputes, particularly where:

• Key interests (such as guardianship, medical treatment, and property) are already the subject of foreign proceedings; and
• Nonparties (like the mother) are at the center of the requested relief.

While the Sixth Circuit does not rest its holding on international comity or abstention doctrines, its reliance on party-specific equity and irreparable-harm constraints shows that traditional equitable limits are powerful gatekeepers against overbroad federal intervention in such disputes.

D. Practical Guidance for Litigators

The decision offers several practical lessons:

• Build a record, not just a narrative. Affidavits, documents, and concrete evidence of past and likely future harm are indispensable; allegations “on information and belief” will not carry the day.
• Tie harm to the defendant. Proving that harm is occurring is not enough; you must establish that this defendant is causing or will imminently cause that harm.
• Link the harm to irreparability. Show how the injury cannot be fixed through a later money award, and why immediate relief is necessary.
• Be realistic about asset freezes. In the absence of an existing property interest or specialized statute, requests for constructive trusts over all of a defendant’s assets are likely to be denied.
• Frame relief so it benefits the party, not primarily nonparties. Overly broad injunctions for nonparties’ benefit risk running afoul of party-specific equity principles.

VII. Conclusion

Shangrila Partnership v. Lemos is formally an unpublished, nonprecedential decision, but it offers a clear and instructive restatement of several foundational principles of federal equitable relief:

• The irreparable harm requirement is indispensable; speculative, hypothetical, or contingent harms do not justify preliminary injunctions.
• Emotional distress, standing alone, is not irreparable harm in the Sixth Circuit, even where alleged to be severe. The ordinary remedy for such injury is money damages.
• Federal courts lack authority under traditional equity principles and Grupo Mexicano to freeze a defendant’s assets or impose a constructive trust solely to secure a future money judgment in a standard tort action.
• Equitable relief is generally party-specific; courts are reluctant to reshape the rights and circumstances of nonparties, particularly where parallel proceedings exist abroad.
• Rule 52(a) does not require exhaustive findings—only enough to permit meaningful appellate review.

In denying preliminary relief to Lazo, the Sixth Circuit does not determine whether Lemos actually committed intentional infliction of emotional distress. Instead, it reaffirms a fundamental structural principle of the federal courts: extraordinary equitable powers are reserved for extraordinary, presently irreparable harms— not for every serious allegation of future emotional injury or potential judgment non-collection.