Citibank, N.A. v. Climate United Fund, et al.

The federal government instructed Citibank, its financial agent, to pause disbursement of certain grant funds. Citibank followed that instruction and pledged to obey any court order regarding the disputed funds. The district court nevertheless issued a preliminary injunction against the government and Citibank, which the en banc court of appeals affirmed in an unreasoned judgment. Neither the district court nor the en banc court offered any meaningful analysis with respect to Citibank, and both failed to consider—let alone apply— most of the required preliminary-injunction factors with respect to Citibank. The question presented is: Whether the preliminary injunction against Citibank for following the federal government’s instructions can remain in place.