Calvin Williams v. Warden FCI Edgefield

Summary

The United States District Court for the District of South Carolina adopted the Magistrate Judge’s Report and Recommendation and granted Calvin Williams’s motion for voluntary dismissal of his 28 U.S.C. § 2241 habeas petition. The court denied the Warden’s motion to dismiss or, alternatively, for summary judgment as moot after finding that Williams had received the requested relief concerning his residential reentry placement and application of First Step Act time credits.

Holdings

1. A petitioner's post-response request to dismiss an action is properly construed as a request for voluntary dismissal under Federal Rule of Civil Procedure 41(a)(2), which requires a court order after the opposing party has responded.
2. Voluntary dismissal should be granted where the opposing party consents and the record shows that dismissal will not cause substantial prejudice to that party.
3. Respondent's motion to dismiss or, alternatively, motion for summary judgment should be denied as moot when the petitioner has received the relief sought and the underlying habeas dispute has been voluntarily dismissed.
4. When no specific objections are filed to a magistrate judge's Report and Recommendation, the district court need only determine that no clear error appears on the face of the record before accepting the recommendation.

Questions Presented

1. Whether the Court should construe Petitioner's motion to dismiss as a motion for voluntary dismissal under Federal Rule of Civil Procedure 41(a)(2).
2. Whether voluntary dismissal should be granted where Respondent consented and would not suffer substantial prejudice.
3. Whether Respondent's motion to dismiss or, alternatively, motion for summary judgment should be denied as moot after the petitioner's requested relief was provided.
4. What standard of review applies to an unobjected-to Report and Recommendation.

Disposition

dismissed