Andre E. Hamilton v. Warden Greene

Summary

The United States District Court for the Middle District of Pennsylvania dismissed Andre E. Hamilton’s 28 U.S.C. § 2241 petition as moot. Hamilton had sought application of earned time credits under the First Step Act but was released from federal custody while the petition was pending. The court concluded that Hamilton failed to demonstrate continuing collateral consequences after being ordered to show cause why the petition should not be dismissed.

Holdings

1. A habeas corpus petition generally becomes moot when the petitioner is released from custody because the petitioner has received the relief sought, unless a live controversy remains through cognizable secondary or collateral consequences.
2. After release from custody, collateral consequences are not presumed; the petitioner must show that a favorable decision would likely redress a continuing injury, and a mere possibility of collateral consequences is insufficient.

Questions Presented

1. Whether Hamilton's § 2241 petition became moot after his release from federal custody.
2. Whether Hamilton demonstrated secondary or collateral consequences of his federal sentence sufficient to preserve an Article III case or controversy.

Disposition

dismissed