BRYAN BONHAM v. THE STATE OF NEVADA JOE LOMBARDO FRANCISCO AGUILAR AARON FORD NEVADA DEPARTMENT OF CORRECTIONS JAMES DZURENDA JEREMY BEAN LT MOREDA SENIOR THOMAS ROSSES SENIOR SABATINO FONTES SGT WILLY CLAYTON AND SGT STEWART (2025)

ORDER OF AFFIRMANCE

Bryan P. Bonham appeals from a district court order denying a motion for a preliminary injunction. Eighth Judicial District Court, Clark County; Anna C. Albertson, Judge.

Bonham initiated the underlying civil rights action against respondents, the State of Nevada, Governor Joe Lombardo, Attorney General Aaron Ford, Secretary of State Franciso Aguilar, the Nevada Department of Corrections (NDOC) and various NDOC employees and officials. Thereafter, Bonham filed a series of motions, including requesting an extension of his copywork debt limit to $500 and requesting a preliminary injunction or, alternatively, a temporary restraining order. In the latter filing, Bonham sought—among other things—to compel the restoration of his yard privileges and to be returned to his prison employment.

This district court ultimately entered an order resolving Bonham's various motions without holding a hearing. As relevant to this appeal, the court first granted in part Bonham's motion to extend his copywork debt limit, extending it by $100 and allowing him to incur up to $200 of copy work debt. Second, with regard to his request for an injunction or a temporary protective order, the court found that it did not appear that respondents “were noticed of this motion and/or the requested relief detailed therein.” As a result, the court held that, “without service perfected on any adverse party” the court would only consider the request for a temporary protective order. As to that request, the court determined the facts Bonham relied on in his motion did not justify such relief. Accordingly, the court denied the motion for a preliminary injunction and temporary protective order. This appeal followed.

District courts have discretion in determining whether to grant or deny a preliminary injunction and thus this court will only reverse the district court's decision on such a request when the court abuses its discretion or bases its decision on an erroneous legal standard or clearly erroneous findings of fact. Excellence Cmty. Mgmt. v. Gilmore, 131 Nev. 347, 351, 351 P.3d 720, 722 (2015).

On appeal, Bonham challenges the denial of his motion for injunctive relief in connection with the decision to extend his copywork limit to $200 rather than $500.¹ More specifically, Bonham argues that he sought the $500 extension of his copywork limit so that he could comply with the service of process requirements set out in NRS 41.031(2) (discussing the waiver of sovereign immunity) and that, given his efforts to extend the copywork limit so he could complete service of his complaint, the denial of his motion for injunctive relief was improper.

As an initial matter, Bonham's argument misunderstands the district court's basis for denying his motion for injunctive relief as the court did so based on his failure to serve respondents with his motion, not based on his failure to serve the complaint. Moreover, while Bonham generally notes the statutory requirements for serving a complaint outlined in NRS 41.031(2) in making this argument, he fails to explain why the $100 extension of the copywork debt limit he received was insufficient to allow him to serve the complaint and/or the motion for injunctive relief. Indeed, Bonham's informal brief does not state what his current copy work debt is, much less argue that he is currently at the debt limit.

Under these circumstances, we conclude Bonham has failed to develop any cogent argument explaining why he needed his copywork limit extended to $500 rather than the $200 he received in order to serve his complaint and motion. See Edwards v. Emperor's Garden Rest., 122 Nev. 317, 330 n.38, 130 P.3d 1280, 1288 n.38 (2006) (providing that we need not consider issues unsupported by cogent argument). Because his assertion that he was somehow unable to serve respondents under these circumstances forms the basis for his challenge to the denial of his motion for injunctive relief, he has failed to demonstrate that the district court abused its discretion in denying this motion based on his failure to serve the motion on respondents. Excellence Cmty. Mgmt., 131 Nev. at 351, 351 P.3d at 722 (setting forth the standard of review of district court orders resolving a request for injunctive relief).

Accordingly, we affirm the district court's decision.²

It is so ORDERED.

Bulla, C.J.

Gibbons, J.

Westbrook, J.

FOOTNOTES

1.   Bonham presents no arguments regarding the remainder of the district court's order, and thus he has waived any arguments regarding the same. See Powell v. Liberty Mut. Fire Ins. Co., 127 Nev. 156, 161 n.3, 252 P.3d 668, 672 n.3 (2011) (providing that issues not raised on appeal are deemed waived).

2.   To the extent Bonham raises other arguments that are not specifically addressed in this order, we have considered the same and conclude they do not present a basis for relief.