Maddox v. Wexford Health Sources, Inc., 528 F. App'x 669

Background

Plaintiff Mannie Maddox, an Illinois inmate, sued under 42 U.S.C. § 1983 alleging deliberate indifference to serious eye conditions (cataracts) and sought a preliminary injunction ordering immediate cataract surgery.
Medical records show repeated optometrist exams from July 2010 to October 2011 noting "poor view" and cataracts, but the clinicians consistently recommended monitoring and follow-ups rather than immediate surgery.
Maddox filed for preliminary relief at the same time as his complaint (February 2012); no defendants had been served when the district court denied the injunction.
After the district court ruling and during this appeal, Maddox received cataract surgery on his right eye (July 2012) and claimed it provided little improvement; his left eye remained untreated.
Defendants argued the appeal was moot because right-eye surgery was performed; Maddox maintained he sought broader relief (series of surgeries, treatment for left eye, eyeglasses, astigmatism care).
The Seventh Circuit held the appeal is not moot as to all relief claimed but affirmed the denial of preliminary injunction because Maddox failed to show a likelihood of success on deliberate-indifference claims or entitlement to immediate relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot after right-eye surgery	Maddox contends he sought a series of surgeries and additional relief (left-eye treatment, eyeglasses, astigmatism care), so right-eye surgery does not moot the case	Defendants argue Maddox sought only immediate right-eye surgery; that remedy has been provided, so appeal is moot	Court: Appeal not fully moot — pleadings and records show claims as to both eyes and effectiveness of treatment not established by defendants
Whether a preliminary injunction ordering immediate surgery was warranted	Maddox argued medical records and risk of total blindness required immediate surgical intervention	Defendants argued records showed monitoring and no recommendation for immediate surgery; no defendant was served when injunction sought	Court: Denial affirmed — Maddox failed to show likelihood of success on deliberate indifference or irreparable harm; injunction cannot be entered against unserved defendants
Whether Maddox established deliberate indifference	Maddox relied on his interpretation of records and asserted urgent need for surgery	Defendants pointed to optometrists' repeated decisions to monitor and to absence of an ophthalmologist's urgent surgical recommendation	Court: Maddox did not present expert-backed evidence showing defendants were deliberately indifferent; records reflect non-surgical monitoring decisions
Whether the district court erred in assessing the medical records	Maddox said records showed surgery was scheduled and court overlooked key entries	Defendants said records show only monitoring and no surgical prescriptions	Court: Maddox misread the records; they document follow-up/monitoring, not scheduled surgery; district court’s assessment correct

Key Cases Cited

Fuller v. Dillon, 236 F.3d 876 (7th Cir. 2001) (plaintiff mootness—relief requested doctrine)
Bd. of Educ. of Oak Park v. Nathan R., 199 F.3d 377 (7th Cir. 2000) (mootness and scope of requested relief)
Friends of the Earth, Inc. v. Laidlaw Environmental Servs., Inc., 528 U.S. 167 (U.S. 2000) (party asserting mootness bears burden of persuasion)
Dorel Juvenile Grp., Inc. v. DiMartinis, 495 F.3d 500 (7th Cir. 2007) (mootness burden discussion)
Lake Shore Asset Mgmt., Ltd. v. Commodity Futures Trading Comm’n, 511 F.3d 762 (7th Cir. 2007) (injunctions require defendants to be served)
Audio Enters., Inc. v. B &W Loudspeakers, 957 F.2d 406 (7th Cir. 1992) (vacating injunction where defendant not served)
Stuller, Inc. v. Steak N Shake Enterprises, 695 F.3d 676 (7th Cir. 2012) (preliminary injunction standards)
Ezell v. City of Chicago, 651 F.3d 684 (7th Cir. 2011) (preliminary injunction standards)