Summary
The United States District Court for the Western District of Pennsylvania adopted a magistrate judge’s Report and Recommendation and denied William R. Gibson’s habeas corpus petition as moot. The petition challenged a 2024 denial of parole, but Gibson was subsequently denied parole again in 2025, superseding the challenged denial. The court also concluded that amendment would be futile and directed the Clerk to close the case.
Holdings
- The Petition was moot because the 2024 parole denial was superseded by the later 2025 parole denial, leaving no meaningful relief that the court could grant concerning the challenged denial.
- The court adopted the Report and Recommendation in whole after reviewing it under the applicable reasoned-consideration standard because Gibson filed no timely and specific objections.
- Any amendment would be futile because the parole denial challenged in the Petition was no longer the basis for Gibson's continued detention.
Questions Presented
- Whether Gibson's habeas petition challenging the 2024 denial of parole became moot after a later parole application was denied in 2025.
- Whether the district court should adopt the magistrate judge's Report and Recommendation when Gibson filed no timely objections.
- Whether amendment of the habeas petition would be futile.
Disposition
dismissed
Cases Cited (15)
- Santiago Rosario v. Philadelphia County, No. CV 19-6017, 2020 WL 8674051, at *1-2 (E.D. Pa. Sept. 24, 2020), report and recommendation adopted sub nom. Rosario v. Philadelphia County, No. 19-CV-6017, 2021 WL 765781 (E.D. Pa. Feb. 26, 2021)(followed)
- Pritchard v. Wetzel, No. 13-5406, 2014 WL 199907, at *2 (E.D. Pa. Jan. 16, 2014)(followed)
- Smallwood v. Meisel, No. 13-3989, 2013 WL 6153238, at *2 (E.D. Pa. Oct. 16, 2013), report and recommendation adopted, 2013 WL 6145123 (E.D. Pa. Nov. 21, 2013)(followed)
- Ogunlana v. Barraza, No. 4:22-CV-01854, 2022 WL 17814213, at *1 (M.D. Pa. Dec. 14, 2022)(followed)
- Shaw v. Wynder, No. Civ.A. 08-1863, 2008 WL 3887642 (E.D. Pa. Aug. 21, 2008)(followed)
- Craig v. Rozum, No. Civ.A. 07-5490, 2008 WL 920346 (E.D. Pa. Apr. 2, 2008)(followed)
- Watson v. Wynder, No. 07-4066 (E.D. Pa. Nov. 27, 2007)(followed)
- PorteYanes v. Lore, No. CIV 4:CV-07-1525, 2007 WL 2852385 (M.D. Pa. Sept. 27, 2007)(followed)
- Allen v. Perini, 424 F.2d 134, 140-41 (6th Cir. 1970)(followed)
- Alexander v. Corbin, No. CIV.A. 11-2727, 2011 WL 5340568, at *1 (E.D. Pa. Sept. 28, 2011), report and recommendation adopted, 2011 WL 5357828 (E.D. Pa. Nov. 3, 2011)(followed)
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Court Document
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