Opinion
Civil 3:22-cv-1560
10-28-2022
MUHAMMAD DUDLEY, Petitioner v. STEPHEN SPAULDING, Respondent
MEMORANDUM
ROBERT D. MARIANI UNITED STATES DISTRICT JUDGE
I. Background
On October 5,2022, Petitioner Muhammad Dudley (“Dudley”), filed a petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241 asserting that he was not credited with his First Step Act time credits. (Doc. 1). On October 27, 2022, Respondent filed a suggestion of mootness informing the Court that Dudley has received his First Step Act time credits. (Doc. 6). 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, Dudley sought the award of additional jail credits under the First Step Act. As Dudley has received the credits he sought, he no longer has a concrete, redressable injury. (See Doc. 6-1). This Court therefore lacks an opportunity to provide Dudley 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.