Opinion
Civil Action 23-3301 (KMW)
08-18-2023
MEMORANDUM ORDER
Hon. Karen M. Williams, United States District Judge
This matter comes before the Court on Petitioner Rafael Sierra-Baez's petition for a writ of habeas corpus filed pursuant to 28 U.S.C. § 2241. (ECF No. 1,) Following an order to answer, the Government filed a response to the petition (ECF No. 5). By way of background, in his petition, Petitioner sought to be declared eligible for and to ultimately receive good time credits under the FirstStep Act. (ECF No. 1.)
In its response to Petitioner's habeas petition, the Government filed a letter in which it informs the Court that Petitioner has been declared eligible for First Step Act credits and has been awarded 45 days of credit thus far, the total number of credits he has earned under the Act. (ECF No. 5 at 1-2.) As such, the Government contends that this matter has become moot as Petitioner has received the relief he sought and no longer has a concrete injury sufficient to continue with this matter. (Id.)
Under Article III of the Constitution, federal courts will only have jurisdiction over a matter where there is a live case or controversy to be resolved. See, e.g., Spencer v. Kemna, 523 U.S. 1, 7 (1998). “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.'” Id. (quoting Lewis v. Continental Bank Corp., 494 U.S. 472, 477-78 (1990)).
Thus, where events provide a petitioner with the relief he sought and render a habeas petition incapable of providing meaningful relief, that petition must be dismissed as moot. See, e..g, Rodney v. Mukasey, 340 Fed.Appx. 761, 764 (3d Cir. 2009); Nunes v. Decker, 480 Fed.Appx. 173, 175 (3d Cir. 2012); Sanchez v. Att'y Gen., 146 Fed.Appx. 547, 549 (3d Cir. 2005).
In this matter, Petitioner sought only to be made eligible for and to receive credits under the First Step Act. The documents and certifications the Government has provided (ECF No. 5-1) clearly show that Petitioner has now been declared eligible for those credits and has received the number of credits he has earned thus far. As Petitioner has now received the ultimate relief he sought, this Court no longer has any meaningfill opportunity to provide Petitioner with relief. His petition is therefore moot, and shall be dismissed as such.
IT IS THEREFORE on this 18lh day of August, 2023, ORDERED that Petitioner's habeas petition (ECF No. 1) is DISMISSED WITHOUT
PREJUDICE as moot; and it is finally
ORDERED that the Clerk of the Court shall serve a copy of this Order upon the Government electronically and upon Petitioner by regular mail, and shall CLOSE the file.