“Even if plaintiff had correctly labeled this claim as a Fourth Amendment one, he could not show that he is entitled to a preliminary injunction. ‘Speculative, remote or future injury’ is not enough to show irreparable harm. Phelan v. Sullivan, No. 5:10-cv-0724, 2011 U.S. Dist. LEXIS 56320, 2011 WL 2118696, at *3 (N.D.N.Y. May 24, 2011) (citing Lyons, 461 U.S. at 111-12). Plaintiff’s claim that he will suffer another detention is just that. He has not demonstrated that New York officials have the legal authority to detain him if he refuses to complete the Traveler Health Form. And even if one official attempted to detain him last time, plaintiff has not shown that this action is likely to recur.” Weisshaus v. Cuomo, 2021 U.S. Dist. LEXIS 5161 (E.D. N.Y. Jan. 12, 2021).
Plaintiff’s claim that she was subjected to a sexualized frisk during the frisk wasn’t fully addressed by defendants’ summary judgment motion in favor of their defense no frisk occurred. Therefore, summary judgment denied. Williams v. Mangano, 2021 U.S. Dist. LEXIS 5144 (E.D. N.Y. Jan. 11, 2021).*