Sigifredo Molina Varela v. Warden Harrison

Summary

The United States District Court for the Western District of Tennessee granted the respondent’s motion to dismiss a federal prisoner’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ treatment of First Step Act earned time credits. The court dismissed the petition as moot because the petitioner had completed his custodial sentence and been released from Bureau of Prisons custody. The court also certified that an appeal would not be taken in good faith and denied leave to proceed in forma pauperis on appeal.

Holdings

1. A § 2241 petition seeking First Step Act earned time credits against custodial time is moot when the petitioner completes his custodial sentence and is released, absent a showing of a concrete collateral consequence. Because Varela sought only credits against completed custodial time and did not challenge his underlying conviction, the court could no longer grant effective relief.
2. The respondent's motion to dismiss was granted, and the § 2241 petition was dismissed as moot.
3. The court certified that an appeal would not be taken in good faith and denied Varela leave to proceed in forma pauperis on appeal.

Questions Presented

1. Whether Varela's § 2241 petition became moot after he completed his custodial sentence and was released from Bureau of Prisons custody.
2. Whether the court should grant the respondent's motion to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6).
3. Whether any appeal should be certified as not taken in good faith and whether Varela should be denied leave to proceed in forma pauperis on appeal.

Disposition

dismissed