Johnny S. Hobbs v. W. Holzapfel

Summary

Proposed Findings and Recommendations in a 28 U.S.C. § 2241 habeas case concerning the application of First Step Act earned time credits. The magistrate judge recommends dismissing the petition and denying the respondent's motion to dismiss as moot because the petitioner was released from custody and no exception to mootness applies.

Holdings

1. Release from custody rendered the petition moot because Petitioner sought only application of earned time credits to advance his release date, and that relief could no longer be granted after his release.
2. The collateral-consequences exception did not apply because Petitioner challenged only the execution of his sentence through application of First Step Act credits, not the validity of his conviction.
3. The capable-of-repetition-yet-evading-review exception did not apply because there was no reasonable expectation that Petitioner would again face the same sentencing circumstances.

Questions Presented

1. Whether Petitioner's release from custody rendered his § 2241 petition seeking application of First Step Act earned time credits moot.
2. Whether the collateral-consequences exception to mootness applied.
3. Whether the capable-of-repetition-yet-evading-review exception to mootness applied.

Disposition

dismissed