Raymond T. DeMeritt v. Frank Bisignano, Commissioner of Social Security
March 16, 2026·8:25-cv-01239-KK-JC·Unpublished·By Raj Patel
The Ninth Circuit affirmed a district court order denying a pro se plaintiff's motion for a preliminary injunction challenging the garnishment of his Social Security benefits. The appellate panel held that the plaintiff failed to demonstrate a likelihood of success on the merits of his claims.
Raymond T. DeMeritt, proceeding pro se, appealed from a district court order denying his motion for a preliminary injunction. The underlying action challenged the garnishment of his Social Security benefits.
The court’s reasoning
The panel reviewed the district court’s decision for an abuse of discretion. The court affirmed because DeMeritt failed to establish that he was likely to succeed on the merits of his claims. The panel noted that when a plaintiff fails to show a likelihood of success on the merits, the court need not consider the remaining elements for a preliminary injunction. The court also cited authority concluding that executing a garnishment order does not require examination beyond the face of the legal process.
What it means going forward
The ruling confirms that challenges to Social Security benefit garnishment via preliminary injunctions will be dismissed if the plaintiff cannot show a likelihood of success on the merits.
