J. S. H. M. v. Wofford, et al.

• Court: District Court, E.D. California
• Decided: February 10, 2026
• Docket: 1:25-cv-01309
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 J. S. H. M., No. 1:25-cv-01309-JLT-SKO (HC) 12 Petitioner, FINDINGS AND RECOMMENDATION TO DISMISS PETITION AS MOOT 13 v. [21-DAY DEADLINE] 14 WOFFORD, et al., 15 Respondents. 16 17 18 Petitioner is a former immigration detainee proceeding with a petition for writ of habeas 19 corpus pursuant to 28 U.S.C. § 2241. 20 On October 16, 2025, the Court issued an order granting a preliminary injunction and 21 directing Respondents to provide Petitioner with a bond hearing. (Doc. 15.) On November 10, 22 2025, Respondents filed a status report advising that Petitioner had received a bond hearing on 23 October 22, 2025, and has been released on bond. (Doc. 17.) 24 For reasons discussed below, the Court recommends that the petition be DISMISSED as 25 moot. 26 DISCUSSION 27 The case or controversy requirement of Article III of the Federal Constitution deprives the 28 Court of jurisdiction to hear moot cases. Iron Arrow Honor Soc’y v. Heckler, 464 U.S. 67, 70 1 (1983); NAACP., Western Region v. City of Richmond, 743 F.2d 1346, 1352 (9th Cir. 1984). A 2 case becomes moot if the “the issues presented are no longer ‘live’ or the parties lack a legally 3 cognizable interest in the outcome.” Murphy v. Hunt, 455 U.S. 478, 481 (1984). The Federal 4 Court is “without power to decide questions that cannot affect the rights of the litigants before 5 them.” North Carolina v. Rice, 404 U.S. 244, 246 (1971) (per curiam) (quoting Aetna Life Ins. 6 Co. v. Hayworth, 300 U.S. 227, 240-241 (1937)). When a prisoner is released from custody, any 7 habeas petition challenging continued detention becomes moot. Fender v. U.S. Bureau of Prisons, 8 846 F.2d 550, 555 (9th Cir.1988). 9 Because Petitioner has been granted the relief he sought and is no longer in custody, the 10 petition is now moot. 11 RECOMMENDATION 12 The Court HEREBY RECOMMENDS that the petition for writ of habeas corpus be 13 DISMISSED. 14 This Findings and Recommendation is submitted to the United States District Court Judge 15 assigned to the case, pursuant to the provisions of 28 U.S.C. § 636 (b)(1)(B) and Rule 304 of the 16 Local Rules of Practice for the United States District Court, Eastern District of California. Within 17 twenty-one (21) days after being served with a copy of this Findings and Recommendation, a 18 party may file written objections with the Court and serve a copy on all parties. Id. The document 19 should be captioned, “Objections to Magistrate Judge’s Findings and Recommendation” and shall 20 not exceed fifteen (15) pages, except by leave of court with good cause shown. The Court will not 21 consider exhibits attached to the Objections. To the extent a party wishes to refer to any 22 exhibit(s), the party should reference the exhibit in the record by its CM/ECF document and page 23 number, when possible, or otherwise reference the exhibit with specificity. Any pages filed in 24 excess of the fifteen (15) page limitation may be disregarded by the District Judge when 25 reviewing these Findings and Recommendations pursuant to 28 U.S.C. § 636 (b)(1)(C). The 26 parties are advised that failure to file objections within the specified time may result in the waiver 27 of rights on appeal. Wilkerson v. Wheeler, 772 F.3d 834, 838-39 (9th Cir. 2014). This 28 recommendation is not an order that is immediately appealable to the Ninth Circuit Court of 1 Appeals. Any notice of appeal pursuant to Rule 4(a)(1), Federal Rules of Appellate Procedure, 2 should not be filed until entry of the District Court's judgment. 3 IT IS SO ORDERED. 4

5 Dated: February 10, 2026 /s/ Sheila K. Oberto . UNITED STATES MAGISTRATE JUDGE 6

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