Saquan Mann v. PA Parole Board, et al.

Mann · United States District Court for the Western District of Pennsylvania · December 23, 2025 · No. 2:24-1015

Summary

This Report and Recommendation addresses Saquan Mann’s 28 U.S.C. § 2254 petition challenging the Pennsylvania Parole Board’s denial of parole. The court recommends dismissing the petition as moot because Mann had completed his sentence and been released from Pennsylvania Department of Corrections custody. It also recommends denying a certificate of appealability.

Holdings

  1. Mann's habeas petition is moot because he is no longer incarcerated and the court cannot provide effective relief concerning the challenged denial of parole.
  2. Money damages are not available in a habeas proceeding.
  3. Mann is not entitled to a certificate of appealability because jurists of reason would not find it debatable that his claims should be dismissed as moot.

Questions Presented

  1. Whether Mann's § 2254 habeas petition became moot after he completed his sentence and was released from Pennsylvania Department of Corrections custody.
  2. Whether Mann was entitled to a certificate of appealability.

Disposition

other

Cases Cited (11)

  • Marine v. Quintana, 347 F. App'x 736 (3d Cir. 2009)(followed)
  • Keitel v. Mazurkiewicz, 729 F.3d 278, 280 (3d Cir. 2013)(followed)
  • Preiser v. Rodriguez, 411 U.S. 475, 484 (1973)(followed)
  • Spencer v. Kemna, 523 U.S. 1, 7, 18 (1998)(followed)
  • Burkey v. Marberry, 556 F.3d 142, 147-48 (3d Cir. 2009)(followed)
  • Lewis v. Continental Bank Corp., 494 U.S. 472, 477-78 (1990)(followed)
  • Allen v. Wright, 468 U.S. 737, 750-51 (1984)(followed)
  • Valley Forge Christian College v. Americans United for Separation of Church & State, Inc., 454 U.S. 464, 471-73 (1982)(followed)
  • Slack v. McDaniel, 529 U.S. 473, 484 (2000)(followed)
  • EEOC v. City of Long Branch, 866 F.3d 93, 100 (3d Cir. 2017)(followed)

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