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Restraining Orders

Johnny Manziel Restraining Order Shows How Emergency TROs Work in Civil Cases

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Posted: 5th March 2026
Susan Stein
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Former NFL quarterback Johnny Manziel has obtained an emergency Temporary Restraining Order (TRO) in a Texas civil lawsuit alleging harassment and reputational harm. The order temporarily restricts certain conduct while the court reviews the dispute at a scheduled hearing.

The lawsuit, filed in Brazos County, Texas, claims that a woman identified in court filings as MaKenzie Carter repeatedly spread false statements about having a personal relationship with Manziel and contacted individuals connected to his personal and professional life.

According to reporting on the court filings, Manziel alleges the conduct included social media posts and direct communications with friends, family members and business contacts.

His lawsuit seeks damages of $250,000 or less, legal fees and a permanent injunction preventing further conduct described in the complaint.

The key legal development is the court’s decision to grant the emergency restraining order. Under civil injunctive relief standards, Temporary Restraining Orders are designed to prevent potential harm while a court considers whether longer-term restrictions are justified.

The order does not determine whether the allegations are true; instead, it establishes temporary legal boundaries while the dispute proceeds.


What We Know So Far

Court filings reported by media outlets indicate that Manziel filed the civil complaint on 27 February in Brazos County, Texas. The lawsuit alleges that MaKenzie Carter repeatedly made online claims that she was in a personal relationship with him.

The complaint further states that communications were sent to individuals within Manziel’s personal and professional circles asserting the existence of such a relationship and warning others not to interfere.

Manziel claims the alleged conduct caused financial and reputational harm. His lawsuit seeks damages capped at $250,000, along with legal fees and a permanent injunction preventing further communications or claims of the type described in the complaint.

A Texas court granted an emergency Temporary Restraining Order shortly after the lawsuit was filed. A hearing has been scheduled where the court will consider whether longer-term restrictions should remain in place while the civil case proceeds.

At this stage, the court has not made findings regarding the underlying allegations.


How Temporary Restraining Orders (TROs) Work

The key legal development in the case is the court’s issuance of an emergency Temporary Restraining Order.

A TRO is a short-term civil order that courts may grant when a party claims that ongoing conduct is causing harm or poses an immediate risk of harm.

Under civil injunctive relief standards, the purpose of the order is to preserve the status quo until a court can conduct a fuller hearing with both sides present.

Because emergency orders are often issued quickly, courts typically rely on preliminary filings rather than a complete evidentiary record.

For that reason, a TRO is not a determination of liability or a final judgment on the facts.

Instead, the order creates temporary legal restrictions that may limit communication, contact or other specified behaviour. The exact scope depends on the wording of the court order.

Even though a TRO is temporary, it is legally binding. Violating the order may expose a person to contempt of court proceedings, which courts treat as a separate legal matter regardless of how the underlying lawsuit is ultimately resolved.


Key Questions People Are Asking

Does a temporary restraining order mean someone is guilty?

No. A Temporary Restraining Order (TRO) does not mean the court has determined that the allegations are true.

Courts issue TROs as precautionary measures when a party claims ongoing harm that could continue before a full hearing takes place. The order simply imposes temporary restrictions while the court reviews the dispute.

The underlying claims must still be examined through the normal civil litigation process.

What is a temporary restraining order (TRO)?

A temporary restraining order is a short-term court order used to restrict certain conduct while a legal dispute is being reviewed.

Courts may grant TROs in cases involving alleged harassment, threats, reputational harm, or other disputes where a judge believes temporary restrictions may be necessary to prevent potential harm before a full hearing occurs.

What happens after a temporary restraining order is granted?

After a TRO is issued, courts typically schedule a follow-up hearing where both sides can present arguments and evidence.

At that hearing, the judge may decide to keep the order in place, modify its terms, or dissolve it entirely. The broader civil lawsuit can continue regardless of whether the temporary order remains.

How long does a temporary restraining order last?

Temporary restraining orders are designed to last only a short period of time.

In many jurisdictions, a TRO remains in effect until a scheduled court hearing where the judge decides whether longer-term restrictions — such as a preliminary injunction, should be imposed.


Possible Procedural Pathways

At the upcoming hearing, the court will decide whether the temporary restraining order should remain in place while the civil lawsuit proceeds.

In some cases, emergency orders are extended into preliminary injunctions that remain in effect until the dispute is resolved. The court may also modify the scope of the order if it determines narrower restrictions are appropriate.

Alternatively, the judge may dissolve the order if the legal threshold for continued injunctive relief has not been met.

Regardless of what happens with the temporary restraining order, the underlying lawsuit seeking damages and a permanent injunction can continue through the civil litigation process.


What the Restraining Order Means for the Case

The key legal development in the Johnny Manziel case is the court’s issuance of an emergency Temporary Restraining Order, which imposes immediate legal restrictions while the dispute is examined further.

A TRO does not resolve the allegations in the lawsuit. Instead, it serves as a temporary measure designed to preserve the status quo while the court determines whether longer-term injunctive relief may be justified.

As the case proceeds, the court will decide whether the temporary order should remain in place, be modified, or be dissolved.

Regardless of that outcome, the existence of court proceedings and public allegations can carry reputational and professional consequences that extend beyond the courtroom.

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About the Author

Susan Stein
Susan Stein is a legal contributor at Lawyer Monthly, covering issues at the intersection of family law, consumer protection, employment rights, personal injury, immigration, and criminal defense. Since 2015, she has written extensively about how legal reforms and real-world cases shape everyday justice for individuals and families. Susan’s work focuses on making complex legal processes understandable, offering practical insights into rights, procedures, and emerging trends within U.S. and international law.
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