On appeal from an order denying a temporary restraining order, the sole issue is whether the district court clearly abused its discretion. Appellant claims that the court abused its discretion by failing to make sufficient findings. We have held that it is error for a district court to rule on a TRO motion without a memorandum accompanying the order showing that it considered these factors. Its failure to address the other factors is not necessarily fatal, for where the district court's finding is on a dispositive Dahlberg factor, a remand for additional findings on the other factors is generally unnecessary. Here, the record supports the district court's determination that appellants did not make a sufficient showing of irreparable harm.
Appellants claim to have suffered a loss of their land.
Technically, that is true, but in reality appellants are in possession of the land and will remain so until the one-year period of redemption expires in November 1996. In addition, the underlying claims will likely be resolved at the trial scheduled for September 1996. The district court did not abuse its discretion in denying the TRO because appellants failed to show irreparable harm.