Whether COVID-19 exposure in prison constitutes an Eighth Amendment violation and whether transfer between state institutions moots injunctive relief

1. Was the exposure to COVID-19 sufficiently serious enough to trigger an Eighth Amendment protection? 2. Does the permanent loss of the sense of smell constitute “unnecessary and wanton infliction of pain ” prohibited by the Eighth Amendment? 3. When injunctive and monetary relief is sought from medical controlled by a state department, does transfer to a different institution still under the control of that state department moot injunctive or monetary relief? 4. Is the Mootness defense best raised by the Defendant or can it be a finding of law and fact found by the Court in an initial screening of a complaint? 5. If the District Court can narrate a perfect summary of a pro se prisoner ’s complaint, that contains what the allegations are, who was involved and when it happened, does that mean the Plaintiff has provided adequate notice under Rule 8? 6. If Rule 8 does not require fact specific allegations, can a pro se Plaintiff allege a group of individuals who acted in concert violated his rights and still meet the personal involvement and individual liability requirement under § 1983? 7. Does the Fourteenth Amendment provide a separate basis for a § 1983 claim? 8. Does the Fourteenth Amendment create a liberty interest in a state prisoner ’s grievance procedure? 2