Luciano v. Semple
A prisoner who requests a preliminary injunction may be required to establish irreparable injury, in the absence of the preliminary injunction. Allegedly, an extraction team that consisted of eight corrections officers entered the plaintiff's cell at Garner Correctional Institution in April 2012, and corrections officers injured the plaintiff, who did not immediately receive medical treatment. The plaintiff sued and apparently alleged that the defendants used excessive force and were deliberately indifferent to a serious medical condition. The plaintiff's complaint requested treatment at the University of Connecticut Health Center for his eyesight and loss of hearing, which allegedly were affected by the April 2012 incident. The plaintiff filed a motion for injunctive relief and requested that he not be incarcerated in the same unit where the corrections officials who extracted the plaintiff in April 2012 work. The defendants argued that the plaintiff's motion was moot, because the plaintiff has been transferred to another corrections facility, MacDougall Correctional Institution. An inmate's requests for injunctive relief may become moot when the inmate is discharged or transferred to another corrections facility. The hallmark of a moot request is that the legal relief sought cannot be furnished. The District Court found that requests for immediate relief in connection with the plaintiff's previous incarceration at Garner Correctional Institution have become moot. The plaintiff failed to produce evidence he has not received adequate medical treatment at MacDougall Correctional Institution and that he requires medical treatment at the University of Connecticut Health Center. The plaintiff failed to establish irreparable harm, which is a required element to obtain injunctive relief. The District Court denied the plaintiff's motion for injunctive relief.