Opinion
Civil 3:23-cv-158
02-16-2023
LEVI CHALLENGER, Petitioner v. WARDEN, FCI-ALLENWOOD, Respondent
MEMORANDUM
Robert D. Mariani United States District Judge.
I. Background
On January 30,2023, Petitioner Levi Challenger (“Challenger”), filed a petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241 asserting that he was entitled to 92 days of credit towards his sentence. (Doc. 1). In response, Respondent filed a suggestion of mootness informing the Court that Challenger has received the requested relief and has been released from the custody of the Bureau of Prisons (“BOP”). (Doc. 7). As a result, Respondent argues that the habeas petition is moot. (Id.). For the reasons set forth below, the Court will dismiss the habeas petition as moot.
II. Discussion
Article III of the Constitution dictates that a federal court may adjudicate “only actual, ongoing cases or controversies.” Lewis v. Continental Bank Corp., 494 U.S. 472,477 (1990); Burkey v. Marberry, 556 F.3d 142,147 (3d Cir. 2009). “This case-or-controversy requirement subsists through all stages of federal judicial proceedings [and for jurisdiction to exist the] parties must continue to have a ‘personal stake in the outcome' of the lawsuit.” Spencer v. Kemna, 523 U.S. 1, 7 (1998) (quoting Lewis v. Continental Bank Corp., 494 U.S. 472,477-78 (1990)). Thus, once a prisoner is released from custody, a habeas challenge to some aspect of his confinement will become moot absent a redressable, continuing, and concrete injury which persists after his release. Id:, see also Burkey, 556 F.3d at 146-50.
In the present case, Challenger sought the award of additional jail credits and requested immediate release from custody. Challenger was released from BOP custody on February 7,2023. (See Doc. 7-1). As Challenger has received the requested relief, he no longer has a concrete, redressable injury. This Court therefore lacks an opportunity to provide Challenger with any meaningful relief in this habeas matter, and his challenge is moot. See Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690,698-99 (3d Cir. 1996) (“If developments occur during the course of adjudication that eliminate a plaintiffs personal stake in the outcome of a suit or prevent a court from being able to grant the requested relief, the case must be dismissed as moot.”).
A separate Order shall issue.