MacDermott v. Rardin

Summary

The United States District Court for the District of Minnesota dismissed without prejudice Troy Nicholas MacDermott’s 28 U.S.C. § 2241 habeas action challenging the revocation of 27 days of good-time credit. The court held that MacDermott’s release from custody rendered the petition moot and that no mootness exception applied. The court also concluded that, even if the case were not moot, the challenged disciplinary determination was supported by some evidence.

Holdings

1. MacDermott's release from custody rendered his habeas petition moot because the court could no longer grant him effective relief concerning the revoked good-time credit.
2. None of the recognized mootness exceptions applied because MacDermott identified no cognizable collateral consequences, no reasonable expectation of repetition, no continuing voluntary cessation, and no class-action claim.
3. The Administrative Procedure Act does not apply to claims concerning the loss of good-time credit because 18 U.S.C. § 3625 precludes APA review of substantive Bureau of Prisons determinations involving such credits.
4. The disciplinary determination was supported by some evidence in the record.
5. A pro se Rule 59(e) motion may be liberally construed as an objection to an R&R, and properly objected-to portions of a dispositive R&R receive de novo review.

Questions Presented

1. Whether MacDermott's release from federal custody rendered his § 2241 petition moot.
2. Whether any exception to mootness applied after MacDermott's release.
3. Whether the court should liberally construe MacDermott's Rule 59(e) motion as an objection to the magistrate judge's Report and Recommendation and review the properly objected-to portions de novo.
4. Whether, assuming the case was not moot, the objections failed because the Administrative Procedure Act does not permit review of the loss of good-time credit and the disciplinary determination was supported by some evidence.

Disposition

dismissed