Tyran Patton v. Warden, FCI-Texarkana

Summary

The United States District Court for the Eastern District of Texas adopted a magistrate judge’s Report and Recommendation in a 28 U.S.C. § 2241 habeas petition challenging the Bureau of Prisons’ refusal to transfer the petitioner to home confinement under the CARES Act. The court dismissed the petition as moot, denied any pending motions, and entered the order on March 20, 2026.

Holdings

1. Because Petitioner filed no objections, he was not entitled to de novo review by the district judge of the magistrate judge's proposed findings, conclusions, and recommendations, and, absent plain error, was barred from appellate review of the unobjected-to factual findings and legal conclusions accepted by the district court.
2. The petition for a writ of habeas corpus was dismissed as moot because the court lacked the power to grant the requested transfer to home confinement.

Questions Presented

1. Whether the district court should adopt the magistrate judge's Report and Recommendation when no objections were filed.
2. Whether the § 2241 petition challenging refusal of transfer to home confinement should be dismissed as moot because the court lacked power to grant the requested relief.

Disposition

dismissed