Jeremy D. Jones v. T. Vaught

Summary

The United States District Court for the District of Minnesota overruled Jeremy D. Jones’s objection to a magistrate judge’s Report and Recommendation and adopted the recommendation. The court dismissed Jones’s 28 U.S.C. § 2254 habeas petition without prejudice as moot, concluding that his requests to restore good-time credits and expunge disciplinary reports presented no ongoing, non-speculative collateral consequences. The court also denied related motions as moot and denied a certificate of appealability.

Holdings

1. The request was moot because Jones had completed the prior sentence and any good-time credits earned during that sentence could not be applied to the sentence he was then serving for a supervised-release violation.
2. The expungement request was moot because Jones failed to identify an ongoing collateral consequence that was sufficiently concrete, traceable to the disciplinary reports, and likely to be redressed by expungement.
3. The objection was overruled, the Report and Recommendation was adopted, and the § 2254 petition was dismissed without prejudice as moot.

Questions Presented

1. Whether Jones's request for restoration of good-time credits was moot after he completed the sentence during which the credits were earned.
2. Whether Jones's request to expunge two disciplinary reports remained justiciable based on alleged collateral consequences to halfway-house or home-confinement placement.
3. Whether the district court should adopt the magistrate judge's Report and Recommendation and dismiss the § 2254 petition without prejudice.

Disposition

dismissed