Opinion
18-20090-01-DDC
04-18-2023
UNITED STATES OF AMERICA, Plaintiff, v. MOISES MARTINEZ-MARTINEZ (01), Defendant.
MEMORANDUM AND ORDER
Daniel D. Crabtree United States District Judge
Defendant Moises Martinez-Martinez has filed a pro se Motion for Compassionate Release (Doc. 54). But because the Bureau of Prisons already has released Mr. Martinez-Martinez, that motion is now moot. The court thus dismisses the motion as moot.
I. Background
On September 19, 2019, Mr. Martinez-Martinez entered a guilty plea to an Information (Doc. 34) charging him with knowingly and intentionally distributing 50 grams or more of methamphetamine. Doc. 37 at 1. On February 3, 2020 the court sentenced him to 70 months' imprisonment. Doc. 44. Then, he was released on February 27, 2023. See Moises Martinez-Martinez, Reg. No. 29424-031, FED. BUREAU OF PRISONS, https://www.bop.gov/inmateloc (last visited Apr. 14, 2023).
II. Discussion
Article III of the United States Constitution limits federal courts' jurisdiction to actual cases or controversies. Iron Arrow Honor Soc'y v. Heckler, 464 U.S. 67, 70 (1983). Under that case-or-controversy requirement, federal courts “lack jurisdiction to decide moot cases,” id. (citing Defunis v. Odegaard, 416 U.S. 312, 316 (1974)), and a case becomes moot when the moving party no longer presents to the court a “live” issue. Murphy v. Hunt, 455 U.S. 478, 481 (1982) (quoting U.S. Parole Comm'n v. Geraghty, 445 U.S. 388, 396 (1980)). A motion for compassionate release no longer presents a live issue when the United States has released the defendant from federal custody. See, e.g., United States v. Lisk, No. 10-CR-40056, 2020 WL 5434126, at *1 (D. Kan. Sept. 10, 2020) (finding motion moot where defendant already had been released from custody); United States v. Sanchez, No. 16-CR-2077-BEN, 2021 WL 5999764, at *1 (S.D. Cal. Dec. 17, 2021) (“When a prisoner is released from custody, the motion for compassionate release becomes moot because there is no further relief this Court can provide.”).
Here, Mr. Martinez-Martinez has secured his release from custody. So, his motion for compassionate release no longer presents a live issue. The motion is moot, and this court lacks jurisdiction to decide it.
IT IS THEREFORE ORDERED BY THE COURT THAT defendant Moises Martinez-Martinez's “Motion for Reduction of Sentence” (Doc. 54) is dismissed as moot.
IT IS SO ORDERED.