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Argued December 3, 2001

A District of Columbia inmate claims that following his transfer from the District’s Lorton Correctional Facility to a Virginia prison pursuant to an interstate compact, Virginia officials used excessive force in restraining him, required him to register under his birth name rather than his religiously inspired legal name, and neglected to give him the insulin he required, resulting in his leg becoming dangerously infected. The inmate also claims that the District denied him access to the courts by failing to transport certain legal documents with him to the Virginia prison, sending them instead to his home. The inmate filed suit in the United States District Court for the District of Columbia, naming as defendants the Commonwealth of Virginia, various Virginia officials, the District of Columbia, various District officials, and the Attorney General of the United States. Affirming the district court’s dismissal of the complaint, we find that (1) all claims against Virginia, its agencies and its officers in their official capacities are either barred by sovereign immunity or mooted by the inmate’s transfer back to a District prison, (2) the district court lacked personal jurisdiction over Virginia officials in their personal capacities, (3) the inmate lacks standing to bring a denial of court access claim, and (4) neither the District nor its officials can be held liable for torts committed by Virginia officials.


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