In the University of Texas et al. v. Camenisch case in 1980, the U.S Supreme Court ruled that a federal court should not grant permanent relief based on preliminary injunction proceedings. The case involved deaf student Fred Friedrich Camenisch who sued the University of Texas for failing to provide sign language interpreters in his graduate classes as required by Section 504 of Rehabilitation Act of 1973. A District Court issued a preliminary injunction requiring the university to pay for an interpreter until final judgment was reached and later granted summary judgment favoring Camenisch without holding further hearings or making additional findings, which was affirmed by Appeals Court. However, Supreme Court vacated these judgments stating that they were based solely on evidence presented during hearing for preliminary injunction which is only meant to preserve status quo while litigation proceeds and does not involve full presentation of facts or law applicable to final determination. Therefore, it held that such proceedings cannot be used as basis for granting permanent relief and remanded case back to District Court.

In the dissenting opinion for University of Texas et al. v. Camenisch, Justice Blackmun argued that the case should have been dismissed as moot because Mr. Camenisch had already graduated and thus could no longer benefit from an injunction requiring his university to provide sign language interpreters during classes. He also disagreed with the majority's decision to vacate the Court of Appeals' judgment on damages, arguing that this issue was not properly before them since it was not included in the petition for certiorari nor briefed or argued by either party at any stage of litigation. Furthermore, he criticized their ruling as a departure from established principles governing interlocutory appeals and remands which would create unnecessary confusion and delay in lower courts.