Eduin Guifarro-Zuniga v. Felipe Martinez Jr
Opinion
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION
EDUIN GUIFARRO-ZUNIGA #56891-510 CASE NO. 2:24-CV-00828 SEC P
VERSUS JUDGE JAMES D. CAIN, JR.
FELIPE MARTINEZ JR MAGISTRATE JUDGE LEBLANC
MEMORANDUM ORDER Petitioner Eduin Guifarro-Zuniga (“Petitioner”) filed a Petition for Writ of Habeas Corpus under 28 U.S.C. § 2241. At the time of filing, Petitioner was an inmate in the custody of the Bureau of Prisons (“BOP”). However, according to BOP’s Online Inmate Locator System, Petitioner has been released from BOP custody.1 “Article III of the Constitution limits federal ‘Judicial Power,’ that is, federal-court jurisdiction, to ‘Cases’ and ‘Controversies.’” U.S. Parole Comm'n v. Geraghty, 445 U.S. 388, 395 (1980). An action is moot “when the court cannot grant the relief requested by the moving party.” Salgado v. Fed. Bureau of Prisons, 220 F. App'x 256, 257 (5th Cir. 2007) (citing Brown v. Resor, 407 F.2d 281, 283 (5th Cir. 1969) and Bailey v. Southerland, 821 F.2d 277, 278 (5th Cir. 1987)). A moot case “presents no Article III case or controversy, and a court has no constitutional jurisdiction to resolve the issue it presents.” Adair v. Dretke, 150 Fed. Appx. 329, 331 (5th Cir. 2005) (citation omitted). Thus, if a
1 https://www.bop.gov/inmateloc/ controversy becomes moot, the case must be dismissed for lack of jurisdiction. Lewis v. Continental Bank Corp., 494 U.S. 472, 477 (1990).
The proper purpose of a habeas petition is to challenge the fact or duration of a petitioner’s confinement. Cook v. Tex. Dep’t of Crim. Justice Transitional Planning Dep’t, 37 F.3d 166, 168 (5th Cir. 1994). In other words, habeas exists solely to “grant relief from unlawful imprisonment or custody and . . . cannot be used properly for any other purpose.” Pierre v. United States, 525 F.2d 933, 935–36 (5th Cir. 1976). A petitioner’s release from the custody of the BOP thus renders his habeas action moot. See, e.g., Bailey v.
Southerland, 821 F.2d 277, 278 (5th Cir. 1987) (dismissing a § 2241 petition as moot following release because “the thrust of [the] petition is to be released from confinement”); Aldaco v. Nash, 693 F. App’x 336, 337 (5th Cir. 2017) (per curiam) (same). Because Petitioner is no longer in custody, his § 2241 petition is moot. Accordingly, IT IS ORDERED, ADJUDGED, and DECREED that this matter be DISMISSED
WITHOUT PREJUDICE. THUS DONE AND SIGNED in Chambers on the 15th day of June, 2026.
__________________________________ JAMES D. CAIN, JR. UNITED STATES DISTRICT JUDGE
Free access — add to your briefcase to read the full text and ask questions with AI
Eduin Guifarro-Zuniga v. Felipe Martinez Jr (Eduin Guifarro-Zuniga v. Felipe Martinez Jr) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.