Leonard Brown v. Warden Newman

Summary

The court dismissed Leonard Brown’s 28 U.S.C. § 2241 habeas petition as moot. The Bureau of Prisons had expunged the disciplinary incident report and restored the 27 days of good conduct time challenged by Brown, leaving no effective relief or redressable collateral injury.

Holdings

1. The petition was moot because the Bureau of Prisons expunged the incident report and restored the 27 days of good-conduct time, leaving the court unable to provide any further habeas relief.
2. Collateral consequences are not presumed when a petitioner challenges the execution or term of a sentence rather than the lawfulness of the underlying conviction; the petitioner must prove a collateral injury that the court can redress.

Questions Presented

1. Whether the § 2241 petition became moot after the Bureau of Prisons expunged the challenged incident report and restored the petitioner's lost good-conduct time.
2. Whether the petitioner demonstrated a continuing collateral injury sufficient to preserve an Article III case or controversy.

Disposition

dismissed