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Case 1:22-cv-00247-DKW-RT Document 85 Filed 12/21/23 Page 23 of 28 PagelD.3083 <br /> irreparable harm where the plaintiff faced threat of prosecution under a state law <br /> conflicting with federal law). Further, HILSTRA additionally points to numerous <br /> intangible injuries flowing from Ordinance 22-7, including hindrances to: (1) <br /> service members' ability to easily transition to or from on-base military housing; <br /> (2) traveling medical practitioners' ability to provide contracted care at Oahu <br /> health care facilities; (3) local residents' ability to transition between homes; (4) <br /> contractors' abilities to perform work on Oahu; (5) displaced residents' ability to <br /> find housing following natural and man-made disasters, including the Red Hill fuel <br /> leak, fire, and flood; (6) neighbor island residents' ease of travel to Oahu for <br /> medical care or events; and (7) other individuals' ability to travel as they prefer. <br /> Dkt. No. 31 at 27 n.27; Dkt. No. 13-1 at 4-5; Complaint at¶ 3. Such intangible <br /> injuries are nearly impossible to remedy retrospectively and have been recognized <br /> by the Ninth Circuit to "qualify as irreparable harm." See Rent-A-Ctr., Inc. v. <br /> Canyon Television & Appliance Rental, Inc., 944 F.2d 597, 603 (9th Cir. 1991). <br /> Second, HILSTRA has also shown that there is no adequate remedy at law <br /> for these intangible harms. "Irreparable harm is traditionally defined as harm for <br /> which there is no adequate legal remedy, such as an award of damages." Arizona <br /> Dream Act Coal. v. Brewer, 757 F.3d 1053, 1068 (9th Cir. 2014). Accordingly, as <br /> HILSTRA has shown that it will sustain irreparable harm absent an injunction, it <br /> - 23 - <br />