Christopher J. Barnett v. Michael Miller

CourtDistrict Court, E.D. Oklahoma
DecidedDecember 30, 2025
Docket6:24-cv-00416
StatusUnknown

This text of Christopher J. Barnett v. Michael Miller (Christopher J. Barnett v. Michael Miller) is published on Counsel Stack Legal Research, covering District Court, E.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christopher J. Barnett v. Michael Miller, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

CHRISTOPHER J. BARNETT,

Petitioner,

v. Case No. 24-CV-416-RAW-GLJ

MICHAEL MILLER,

Respondent,1

OPINION AND ORDER Petitioner Christopher J. Barnett (“Barnett”), a state prisoner appearing pro se, brought this action for habeas corpus relief under 28 U.S.C. § 2241. Dkt. 1. Respondent filed a Motion to Dismiss (“Motion”) in response to the Petition. Dkt. 21. Having reviewed the Petition (Dkt. 1), the Motion to Dismiss (Dkt. 21) and applicable law, the court grants the Motion. I. Barnett’s claim At the time of filing his Petition, September 21, 2024, Barnett was a state prisoner at the Oklahoma State Penitentiary. Dkt. 1 at 1, 9.2 Barnett received a “Class X” offense and lost 2063 earned time credits. Id. at 2. Barnett appealed this outcome, and the Administrative Review Authority (“ARA”) ordered a disposition hearing within fifteen days of its order. Id. at 3, 6. Barnett’s only ground for relief is that he “is still Level 1 & the mandate was not followed.” Id. at

1 Barnett presently is incarcerated at the Allen Gamble Correctional Center, and Michael Miller is the current warden of that facility. The court therefore substitutes Michael Miller, Warden, in place of William “Chris” Rankins as party Respondent. See Rule 2(a), Rules Governing Section 2254 Cases in the United States District Courts. The Clerk of Court shall note on the record this substitution. 2 The court’s citations refer to CM/ECF header pagination. 6. Barnett seeks “full dismissal …, [his] 2063 earned credits restored, my level 4 restored, my lost gang pay restored along with cost and fees of this action.” Id. at 1, 8. II. Respondent’s Motion

Respondent outlined the history of Barnett’s offense and lost credits in the Motion. See Dkt. 21. On May 13, 2024, Barnett received an offense report for prohibited possession of computer equipment. Dkt. 21 at 1; see also Dkt. 21-3 at 1. On May 20, 2024, Barnett was found guilty of the disciplinary violation, and the offense was classified as a “Class X” misconduct. Dkt. 1 at 2; see also Dkt. 21-3 at 8. Therefore, he lost all earned credits. Dkt. 1 at 2; see also Dkt. 21- 3 at 8. Barnett unsuccessfully appealed the outcome of the disciplinary hearing to the facility head. Dkt. 1 at 2; see also Dkt. 21-3 at 9-10. Barnett then appealed the discipline to the ARA, who determined the charge should be amended to Class A misconduct for “possession of an item not authorized by the facility.” Dkt. 1 at 2; see also Dkt. 21-3 at 15. The ARA also ordered a new hearing be granted to Barnett. Dkt. 1 at 2; see also Dkt. 21-3 at 15. A Class A offense does not carry the sanction of lost earned credits.

Dkt. 1 at 2. On August 22, 2024, Barnett again appealed to the ARA the Class A Misconduct. Id.; see also Dkt. 21-3 at 16. The ARA advised Barnett the Class A Misconduct was not appealable to the ARA. Dkt. 1 at 2; see also Dkt. 21-3 at 18. On September 13, 2024, and September 19, 2024, Barnett notified the ARA he had not received the re-hearing as ordered by the ARA. Dkt. 1 at 2; see also Dkt. 21-3 at 19-20. On September 24, 2024, the ARA fully dismissed and expunged the misconduct proceeding and ordered the restoration of earned credits. Dkt. 1 at 2-3; see also Dkt. 21-3 at 21. Respondent represents Barnett’s revoked credits have been restored. Dkt. 1 at 3. Respondent also states Barnett has not submitted any further grievances or appeals related to the earned credits, his level or any other issue related to the disciplinary hearing. Id.; see also Dkt. 21-5. Therefore, Respondent argues Barnett’s claim is moot and any requested relief that has not been mooted by the restoration of credits is unexhausted. See Dkt. 21 at 4-8. Barnett did not respond Respondent’s Motion.

III. Analysis The court agrees the majority of Barnett’s Petition is moot. Federal courts “may only decide actual ongoing cases or controversies.” Prier v. Steed, 456 F.3d 1209, 1212 (10th Cir. 2006) (citation omitted). So, “if an event occurs while a case is pending ... that makes it impossible for the court to grant ‘any effectual relief … to a prevailing party,’” the case becomes moot. Id. at 1213 (citation and internal quotations omitted). It is Barnett’s burden to establish this court has jurisdiction. See Wilcox v. Aleman, 43 F. App’x. 210, 212 (10th Cir. 2002) (holding habeas “petitioner has the burden of demonstrating the existence of sufficient collateral consequences to save the action from the mootness death knell”). So, once Respondent factually attacked jurisdiction, Barnett was required to “present affidavits or

other evidence sufficient to establish the court’s subject matter jurisdiction by a preponderance of the evidence.” Robinson v. Union Pac. R.R., 245 F.3d 1188, 1191 (10th Cir. 2001) (citation omitted). A. Dismissal of disciplinary action and restoration of earned credits As an initial matter, Barnett has failed to carry this burden. Respondent presents evidence that his disciplinary action has been dismissed and his 2063 earned credits were restored. Dkts. 21-2 and 21-3 at 21. Barnett does not dispute this contention or counter it with any evidence. Accordingly, this portion of Barnett’s claim is moot and dismissed. See Thomas v. Chester, 561 F. App’x 656 (10th Cir. 2014)3 (affirming the district court’s dismissal of petitioner’s § 2241 petition on grounds prison officials’ restoration of all his earned credits rendered his petition moot); see also Wiggins v. Stancil, Case No. 19-CV-1653-RBJ, 2019 WL 4464135 (D. Colo. Sep. 18, 2019) (unpublished) (finding petitioner’s requests for expungement of disciplinary conviction and

restoration of good-time credits were moot by the expungement of the disciplinary conviction and restoration of credits). B. Level 4 restoration Barnett claims because of the disciplinary proceeding his level was changed from 4 to 1. Dkt. 1 at 7. And, it has not been restored. See id. at 8. 4 The court concludes Barnett’s challenge to his security classification is not cognizable in a § 2241 action. “Section 2241 requires a petitioner to challenge the fact of—not the conditions of—confinement.” Stanko v. Quay, 356 F. App’x 208, 210 (10th Cir. 2009). To the extent Barnett argues he is entitled to a lesser classification, he must pursue this claim under Bivens ,403 U.S. 388 (1971). Id. Furthermore, Respondent alleges this request is unexhausted. To the extent it is cognizable

pursuant to § 2241, it is subject to dismissal for lack of exhaustion. According to the Tenth Circuit, “[t]he exhaustion of available administrative remedies is a prerequisite for § 2241 habeas relief....” Garza v. Davis, 596 F.3d 1198, 1203 (10th Cir. 2010). Respondent argues Barnett has not submitted any further grievances or appeals related to his “earned credit level or any other issue related to the disciplinary proceeding.” Dkt. 21 at 3; see also Dkt. 21-5. Barnett does not dispute

3 The court cites all unpublished decisions herein as persuasive authority. Fed. R. App. P. 32.1(a); 10th Cir. R. 32.1(A). 4 The court notes in his December 5, 2024 “Motion for Summary Judgment,” Barnett states he is “now Level 2.” Dkt. 22 at 1. this contention.

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Related

Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Robinson v. Union Pacific Railroad
245 F.3d 1188 (Tenth Circuit, 2001)
Prier v. Steed
456 F.3d 1209 (Tenth Circuit, 2006)
Stanko v. Quay
356 F. App'x 208 (Tenth Circuit, 2009)
Garza v. Davis
596 F.3d 1198 (Tenth Circuit, 2010)
Thomas v. Chester
561 F. App'x 656 (Tenth Circuit, 2014)

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Bluebook (online)
Christopher J. Barnett v. Michael Miller, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-j-barnett-v-michael-miller-oked-2025.