Ronnie Bee Cislo v. McKayla and LaPorte County Sheriff

Summary

The court grants the LaPorte County Sheriff’s Rule 12(b)(1) motion to dismiss the official-capacity claim seeking injunctive relief for opioid-withdrawal treatment. Because the plaintiff was transferred from the LaPorte County Jail and showed no likelihood of retransfer, the court concludes that the injunctive-relief claim is moot and dismisses the Sheriff. The case proceeds solely on the individual-capacity claim against Nurse McKayla.

Holdings

1. A prisoner's request for injunctive relief against officials of a former prison is moot after the prisoner is transferred to another prison unless he demonstrates that he is likely to be transferred back.
2. The court lacked subject matter jurisdiction over Cislo's official-capacity claim against the LaPorte County Sheriff because the claim was moot.

Questions Presented

1. Whether Cislo's request for permanent injunctive relief against the LaPorte County Sheriff became moot after Cislo was transferred from the LaPorte County Jail to another correctional facility.
2. Whether the court therefore lacked subject matter jurisdiction over the official-capacity claim against the Sheriff.

Disposition

dismissed