Blackwell v. Sage

• Court: District Court, M.D. Pennsylvania
• Decided: July 11, 2023
• Docket: 3:23-cv-00062
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA MATTHEW V. BLACKWELL, :

Petitioner : CIVIL ACTION NO. 3:23-0062 v : (JUDGE MANNION)

WARDEN SAGE, :

Respondent : MEMORANDUM I. Background Matthew V. Blackwell, a former inmate confined in the Schuylkill Federal Correctional Institution, Minersville, Pennsylvania, filed the above captioned petition for writ of habeas corpus, pursuant to 28 U.S.C. §2241.

(Doc. 1, petition). Blackwell challenges the Bureau of Prisons’ (BOP) decision to apply time credits under the First Step Act toward home confinement instead of early release. Id. He also disputes the BOP’s decision to stop applying time

credits for inmates when they are within 18 months of their release date. Id. As relief, Blackwell requests he be awarded “all of my First Step Act credits…” Id. A review of the Federal Bureau of Prisons Inmate Locater reveals that Blackwell was released from SCI-Schuylkill custody on June 9, 2023. See

https://www.bop.gov/inmateloc/. For the reasons set forth below, the instant petition will be dismissed as moot.

II. Discussion The case or controversy requirement of Article III, §2 of the United States Constitution subsists through all stages of federal judicial

proceedings. Parties must continue to have a “personal stake in the outcome of the lawsuit.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477–78 (1990); Preiser v. Newkirk, 422 U.S. 395, 401 (1975). In other words, throughout the course of the action, the aggrieved party must suffer or be

threatened with actual injury caused by the defendant. Lewis, 494 U.S. at 477. The adjudicatory power of a federal court depends upon “the

continuing existence of a live and acute controversy.” Steffel v. Thompson, 415 U.S. 452, 459 (1974) (emphasis in original). “The rule in federal cases is that an actual controversy must be extant at all stages of review, not merely at the time the complaint is filed.” Id. at n.10 (citations omitted). “Past

exposure to illegal conduct is insufficient to sustain a present case or controversy ... if unaccompanied by continuing, present adverse effects.” Rosenberg v. Meese, 622 F.Supp. 1451, 1462 (S.D.N.Y. 1985) (citing

O’Shea v. Littleton, 414 U.S. 488 (1974)). “[A] petition for habeas corpus relief generally becomes moot when a prisoner is released from custody before the court has addressed the merits of the petition.” Lane v. Williams, 455 U.S. 624, 631 (1982).

In the instant case, because Blackwell has been released from custody, his habeas petition has been rendered moot. See Rodriguez-Leon v. Warden, 602 F. App’x 854 (3d Cir. 2015); Scott v. Schuylkill FCI, 298 F.

App’x 202 (3d Cir. 2008); Scott v. Holt, 297 F. App’x 154 (3d Cir. 2008).

III. Conclusion

For the reasons stated above, the petition for a writ of habeas corpus will be DISMISSED. An appropriate order will follow.

s/ Malachy E. Mannion MALACHY E. MANNION United States District Judge Date: July 11, 2023 22-0062-01