Bobby Tatum v. Donald Craig

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted November 13, 2025*
Decided November 14, 2025
Before
MICHAEL B. BRENNAN, Chief Judge
DIANE S. SYKES, Circuit Judge
AMY J. ST. EVE, Circuit Judge
No. 24-2084
BOBBY TATUM,
Plaintiff-Appellant,
v.
DONALD CRAIG, et al.,
Defendants-Appellees.
Appeal from the
United States District Court for the
Southern District of Illinois.
No. 24-cv-1183-NJR
Nancy J. Rosenstengel,
Chief Judge.
O R D E R
Bobby Tatum, an Illinois prisoner, appeals the denial of his motion for injunctive
relief seeking a transfer to a different prison. But while this appeal was pending, he was
transferred to another facility, so we dismiss the appeal as moot.
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-2084 Page 2
In early 2024, Tatum brought this civil-rights lawsuit against defendants at the
Shawnee Correctional Center in Vienna, Illinois. See 28 U.S.C. § 1983. Tatum alleges that
in August 2023, Warden Darren Galloway ordered Sergeant Seth Plott, Officer Donald
Craig, Lieutenant Billy Austin, Lieutenant Kelley Beal, and Lieutenant Christian to beat
him up in retaliation for lawsuits and grievances he filed against prison staff members.
He claims that Austin, Beal, and Christian sexually assaulted him with a stick; that
Sergeant Stroud slammed his face into a window while transporting him to segregation;
and that when a nurse arrived to treat him, Beal told her to leave and then placed him
in a different segregation cell that was covered in blood and feces.
In May 2024, the district judge screened Tatum’s complaint under 28 U.S.C.
§ 1915A and permitted him to proceed on a claim against Galloway, Plott, Craig,
Austin, Christian, Beal, and Stroud for assaulting him in retaliation for filing grievances
and lawsuits in violation of his rights under the First Amendment. The judge also
permitted Tatum to proceed on a claim against Galloway, Plott, Craig, Austin,
Christian, Beal, and Stroud for excessive force in violation of his rights under the Eighth
Amendment. And the judge permitted him to proceed on a claim against Beal for
placing him in an unsanitary cell in violation of his rights under the Eighth
Amendment.
As relevant to this appeal, Tatum filed three motions for injunctive relief. His
first motion, filed in May 2024, asserted that he feared retaliation and asked that he be
released from prison and placed on home monitoring. The judge denied this motion
because he had not alleged that his life was in danger or that he was facing threats from
the defendants. A few weeks later, Tatum filed his second motion, asking to be
transferred to a different prison. The judge denied this motion for the same reasons that
she denied the first.
In June 2024 Tatum filed this appeal challenging the denial of his second motion
for injunctive relief. In February 2025, while this appeal has been pending, Tatum was
transferred to Pinckneyville Correctional Center in Pinckneyville, Illinois.
Also in February, Tatum filed a third motion for injunctive relief seeking transfer
from Pinckneyville to a medium-security prison in the Northern District of Illinois. He
asserted that his transfer from the medium-security facility at Shawnee was part of an
ongoing campaign of retaliation for his lawsuits and grievances. In May 2025 a
magistrate judge denied Tatum’s third motion for injunctive relief because his transfer
to Pinckneyville occurred nearly two years after the alleged assaults, and injunctive

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No. 24-2084 Page 3
relief must be related to the underlying allegations in the lawsuit. Tatum did not appeal
this order.
Tatum contends that his appeal from the judge’s second order is not moot,
arguing that his transfer to Pinckneyville—a facility he mistakenly labels as maximum
security—was harmful because it stemmed from an ongoing campaign of retaliation.
But his transfer moots his claim for injunctive relief, which pertains only to the specific
conditions at Shawnee. See Calhoun v. DeTella, 319 F.3d 936, 939 (7th Cir. 2003). Tatum
does not suggest that he faces any retaliatory threats at Pinckneyville related to lawsuits
or grievances that he filed at Shawnee, see Hildreth v. Butler, 960 F.3d 420, 431 (7th Cir.
2020), or that any defendant here is involved in the prison administration at
Pinckneyville, see Ortiz v. Downey, 561 F.3d 664, 668 (7th Cir. 2009); see also Lehn v.
Holmes, 364 F.3d 862, 871–72 (7th Cir. 2004).
DISMISSED

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