Holt v. United States

E.D. Missouri

Holt v. United States

DecidedJuly 16, 2025

Docket4:24-cv-00065

StatusUnknown

This text of Holt v. United States (Holt v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Holt v. United States, (E.D. Mo. 2025).

Pincite

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LARRY JOSEPH HOLT, ) ) Petitioner, ) ) v. ) Case No. 4:24-cv-00065-SNLJ ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM AND ORDER

This matter is before the Court on Petitioner Larry Joseph Holt’s Amended Motion Pursuant to 28 U.S.C. § 2255. [Doc. 11]. For the reasons stated below, the motion is denied as moot. On September 2, 2015, Holt pled guilty to one count of conspiracy to distribute heroin and two counts of being a felon in possession of a firearm. [Docs. 34, 35]. On July 6, 2016, Holt was sentenced as an armed career criminal to the minimum statutory term of 180 months. [Docs. 61, 62]. In his original § 2255 motion [Doc. 1] and the Amended § 2255 motion [Doc. 11], Holt requests that his sentence be vacated and that he be resentenced without the armed career criminal designation. He argues that because one of the predicate offenses for the armed career criminal designation was expunged on October 10, 2023, his sentence is illegal and must be vacated. Holt also filed a Motion for Sentence Reduction Under 18 U.S.C. § 3582(c)(1)(A) in United States of America v. Larry Joseph Holt, No. 4:15-cr-00137-SNLJ. On April 7, 2025, the Court granted that motion and reduced Holt’s sentence to time served as of April 22, 2025. Because Holt’s § 2255 motion only challenges his term of imprisonment, which has now expired, and does not challenge the underlying conviction or his supervised release, his motion is moot. Owens v. United States, 930 F.3d 989, 990-91 (8th Cir. 2019) (holding that release renders a § 2255 motion moot when the movant challenges only his term of imprisonment and not the term of supervised release). After his release from prison, “the court cannot grant any effectual remedy, because [Holt] has obtained all of the relief that he sought.” /d. at 990. “There is thus no ongoing case or controversy.” Id. Accordingly, IT IS HEREBY ORDERED that Petitioner Larry Joseph Holt’s Amended Motion Pursuant to 28 U.S.C. § 2255 [Doc. 11] is DENIED as moot. SO ORDERED this 16" day of July, 2024.

/ LZD4 Z. beak STEPHEN N. LIMBAUGH, JR. SENIOR UNITED STATES DISTRICT JUDGE

Free access — add to your briefcase to read the full text and ask questions with AI

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LARRY JOSEPH HOLT, ) ) Petitioner, ) ) v. ) Case No. 4:24-cv-00065-SNLJ ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM AND ORDER

This matter is before the Court on Petitioner Larry Joseph Holt’s Amended Motion Pursuant to 28 U.S.C. § 2255. [Doc. 11]. For the reasons stated below, the motion is denied as moot. On September 2, 2015, Holt pled guilty to one count of conspiracy to distribute heroin and two counts of being a felon in possession of a firearm. [Docs. 34, 35]. On July 6, 2016, Holt was sentenced as an armed career criminal to the minimum statutory term of 180 months. [Docs. 61, 62]. In his original § 2255 motion [Doc. 1] and the Amended § 2255 motion [Doc. 11], Holt requests that his sentence be vacated and that he be resentenced without the armed career criminal designation. He argues that because one of the predicate offenses for the armed career criminal designation was expunged on October 10, 2023, his sentence is illegal and must be vacated. Holt also filed a Motion for Sentence Reduction Under 18 U.S.C. § 3582(c)(1)(A) in United States of America v. Larry Joseph Holt, No. 4:15-cr-00137-SNLJ. On April 7, 2025, the Court granted that motion and reduced Holt’s sentence to time served as of April 22, 2025. Because Holt’s § 2255 motion only challenges his term of imprisonment, which has now expired, and does not challenge the underlying conviction or his supervised release, his motion is moot. Owens v. United States, 930 F.3d 989, 990-91 (8th Cir. 2019) (holding that release renders a § 2255 motion moot when the movant challenges only his term of imprisonment and not the term of supervised release). After his release from prison, “the court cannot grant any effectual remedy, because [Holt] has obtained all of the relief that he sought.” /d. at 990. “There is thus no ongoing case or controversy.” Id. Accordingly, IT IS HEREBY ORDERED that Petitioner Larry Joseph Holt’s Amended Motion Pursuant to 28 U.S.C. § 2255 [Doc. 11] is DENIED as moot. SO ORDERED this 16" day of July, 2024.

/ LZD4 Z. beak STEPHEN N. LIMBAUGH, JR. SENIOR UNITED STATES DISTRICT JUDGE

Cite This Page — Counsel Stack

Bluebook (online)

Holt v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holt-v-united-states-moed-2025.

Opinion

Related

Cite This Page — Counsel Stack