Summary
The United States District Court for the Eastern District of Michigan dismissed Michael McGuire’s 28 U.S.C. § 2241 habeas petition as moot. McGuire sought application of First Step Act credits and transfer to prerelease custody, but he was transferred from FCI Milan to the Residential Reentry Management Program while the case was pending.
Topics
Practice areas
Questions Presented
- Whether McGuire's § 2241 petition seeking transfer from FCI Milan to prerelease custody became moot after the Bureau of Prisons transferred him to prerelease custody.
- Whether the court needed to decide the government's arguments concerning the cognizability of the requested relief under § 2241 or exhaustion of administrative remedies.
Holdings
- The petition was moot because McGuire received the requested transfer from FCI Milan to prerelease custody, leaving no live controversy concerning that relief.
- The court did not reach the government's arguments concerning cognizability under § 2241 or exhaustion of administrative remedies because the petition was moot.
Key quotations
“Thus, as McGuire has been released from FCI Milan to prerelease custody, his petition against the Milan warden seeking that relief (ECF No. 1) is hereby DISMISSED AS MOOT.” (Disposition paragraph)
“Although Congress has authorized the BOP to utilize either or both of these types of pre-release custody, it does not prescribe when one should be used rather than the other, nor does it mandate the use of home confinement.” (Footnote 2)
Factual background
Michael McGuire was serving a 120-month federal sentence at FCI Milan after pleading guilty in the Northern District of Iowa to four cyberstalking counts. He alleged that the Bureau of Prisons misapplied his First Step Act earned time credits and failed to release him timely to prerelease custody or home confinement. On December 17, 2025, he was transferred from FCI Milan to the Residential Reentry Management Program in Minneapolis, a form of prerelease community confinement.
Procedural history
McGuire filed a pro se § 2241 petition on July 29, 2025, against the warden of FCI Milan. He later amended the petition with a time-credit assessment document. The government responded on December 18, 2025, advising that McGuire had been released to the Residential Reentry Management Program in Minneapolis on December 17, 2025, and arguing that the petition was moot. After receiving no timely reply, the court dismissed the petition as moot.