Jeffrey Cook v. Harold Clarke, et al.
Opinion
CLERKS OFFICE US DISTRICT COURT AT ROANOKE, VA FILED IN THE UNITED STATES DISTRICT COURT August 07, 2026 FOR THE WESTERN DISTRICT OF VIRGINIA LAURA A. AUSTIN, CLERK ROANOKE DIVISION By: /s/ M. Poff DEPUTY CLERK JEFFREY COOK, ) Plaintiff, ) Civil Action No. 7:24cv00249 ) v. ) MEMORANDUM OPINION ) HAROLD CLARKE, et al., ) By: Robert S. Ballou Defendants. ) United States District Judge
Jeffrey Cook, a Virginia inmate proceeding pro se, filed a civil rights complaint, pursuant to 42 U.S.C. § 1983 against five individuals employed at or associated with Red Onion State Prison or Keen Mountain Correctional Center. Cook seeks to hold Defendants responsible for alleged violations of his Eighth and Fourteenth Amendment rights relating to a shoulder injury he sustained while incarcerated at Red Onion. The case is presently before the court on Cook’s Motion for Preliminary Injunction requesting the “Court to grant a Preliminary Injunction to receive the treatment [Cook] needs without having to risk further injury or loss of life.” Dkt. 39. Cook requests that the Court issue a preliminary injunction for “#1) A change in the transportation vehicle [to and from medical appointments]... #2) A change in Blood Pressure and pain medication ... [and] #3) A transfer to a facility much closer [to medical providers].” Jd. For the following reasons, the Motion is denied as moot. According to public record, Virginia Department of Corrections (VDOC) transferred Cook to Greensville Correctional Center on April 27, 2026 and to Nottoway Correctional Center on July 29, 2026. “[A]s a general rule, a prisoner’s transfer or release from a particular prison [or jail] moots his claim for injunctive ... relief with respect to his incarceration there.” Rendelman v. Rouse, 569 F.3d 182, 186 (4th Cir. 2009); Firewalker-Fields v. Lee, 58 F.4th 104, 113-114 (4th Cir. 2023). “The reasoning for finding mootness in such a context are clear.”
Incumaa v. Ozmint, 507 F.3d 281, 287 (4th Cir. 2007). Once an inmate is removed from the challenged environment, he “has no further need for such … injunctive relief, for he is free of the policy or practice that provoked his lawsuit in the first place.” Id. Accordingly, I will deny his Motion for Preliminary Injunction. Dkt. 39. A separate order will be entered this day.
Enter: August 7, 2026 //s/ Robert S. Ballou Robert S. Ballou United States District Judge
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