Seth Micah Hubbard v. David Cox, et al.

Summary

The United States District Court for the Western District of Virginia denied Seth Micah Hubbard’s motion for a preliminary injunction as moot. Hubbard, a Virginia inmate diagnosed with celiac disease, sought transfer from the Western Virginia Regional Jail based on allegations that he was not provided a medically necessary gluten-free diet; the court found that his transfer to Virginia Department of Corrections custody mooted the requested injunctive relief.

Holdings

1. A prisoner's transfer from the particular jail or prison challenged in the action moots a claim for injunctive relief concerning conditions at that facility when the prisoner is no longer subject to the challenged environment. Because Hubbard had been transferred from the Western Virginia Regional Jail, his motion for preliminary injunction was moot.

Questions Presented

1. Whether Hubbard's motion for preliminary injunctive relief concerning his confinement at the Western Virginia Regional Jail became moot after he was transferred from that facility.

Disposition

denied