Samuel John v. U.S. Immigration and Customs Enforcement

Summary

A United States magistrate judge recommends dismissing Samuel John’s amended 28 U.S.C. § 2241 habeas petition without prejudice as moot. The recommendation concludes that John’s claims challenging his immigration detention became moot after he was removed from the United States on December 16, 2025.

Holdings

1. A habeas petition challenging only the lawfulness or duration of immigration detention is moot when the petitioner is no longer detained and has been removed from the United States.
2. The amended petition should be dismissed without prejudice as moot.

Questions Presented

1. Whether John's § 2241 challenge to the lawfulness and duration of his immigration detention remained a live Article III controversy after he was removed from the United States.
2. Whether the amended habeas petition should be dismissed without prejudice as moot.

Disposition

dismissed