King v. Ciolli

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 19, 2024
Docket23-1201
StatusUnpublished

This text of King v. Ciolli (King v. Ciolli) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
King v. Ciolli, (10th Cir. 2024).

Opinion

Appellate Case: 23-1201 Document: 010111018764 Date Filed: 03/19/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT March 19, 2024 _________________________________ Christopher M. Wolpert Clerk of Court ERIC KING,

Petitioner - Appellant,

v. No. 23-1201 (D.C. No. 1:23-CV-00519-CNS) ANDREW CIOLLI, Warden, Florence (D. Colo.) FCC and ADX, United States Bureau of Prisons,

Defendant - Appellee. _________________________________

ORDER AND JUDGMENT* _________________________________

Before HOLMES, Chief Judge, BALDOCK, and MATHESON, Circuit Judges. _________________________________

Petitioner-Appellant Eric King appeals from the denial of his 28 U.S.C. § 2241

petition for a writ of habeas corpus. We conclude that Mr. King’s release from prison

during the pendency of this appeal has mooted his petition. Accordingly, we vacate the

district court’s judgment, remand with instructions to dismiss the petition as moot, and

dismiss this appeal.

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See FED. R. APP. P. 34(a)(2); 10TH CIR. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Federal Rule of Appellate Procedure 32.1(a) and Tenth Circuit Rule 32.1(A). Appellate Case: 23-1201 Document: 010111018764 Date Filed: 03/19/2024 Page: 2

I

A

Mr. King was convicted of using explosive materials to commit arson in the

Western District of Missouri in 2016. He received a sentence of ten years’ imprisonment,

with three years of supervised release to follow. Throughout his imprisonment, Mr. King

was housed at a variety of facilities. In 2022, he was transferred to the Administrative

Maximum Facility (“ADX”) in Florence, Colorado.

On February 27, 2023, while in custody at the ADX, Mr. King filed a habeas

petition pursuant to 28 U.S.C. § 2241, and a motion for a temporary restraining order

(“TRO”) and hearing in the District of Colorado. In the habeas petition, Mr. King

asserted four grounds for relief, arguing that:

(1) [his sentence was] unlawfully prolonged . . . based on arbitrary and capricious disciplinary proceedings lacking in Due Process and depriving him of good time credit[,]

(2) [he was] serving this unlawfully prolonged sentence at the ADX based on a bias motivated and secretive ADX placement process devoid of Due Process[,]

(3) [t]he Bureau of Prisons . . . unlawfully prolonged this cruel and unusual sentence based in part on over sixteen hundred (1600) days of designation in segregated housing without meaningful review or opportunity to be heard in violation of federal law, preventing Mr. King’s ability to earn good time credit, also causing Mr. King an unlawfully prolonged Sentence[, and]

(4) [he was] serving an unnecessarily prolonged sentence at the ADX where he [wa]s unable to access prerelease programs pursuant to what appears to be an unreviewable Ultra Vires Special Administrative Measure (SAM) policy and process enacted in violation of the Administrative Procedure Act (“APA”) and contrary to the judicial review power of the courts.

2 Appellate Case: 23-1201 Document: 010111018764 Date Filed: 03/19/2024 Page: 3

Aplt.’s App., Vol. I, at 6–7 (Pet. for Writ Habeas Corpus, filed Feb. 27, 2023). In his

TRO motion, Mr. King requested that the court enjoin the Bureau of Prisons (“BOP”) and

the ADX warden from:

(1) [h]ousing Mr. King at the ADX on an unlawfully prolonged sentence,

(2) [t]ransferring Mr. King out of [the] Court’s jurisdiction,

(3) [e]ndangering Mr. King through manipulation of his housing placement,

(4) [i]mposing arbitrary and unnecessary special conditions on Mr. King’s release, and

(5) [i]nterfering with [the] exercise of Mr. King’s rights, to include his right to counsel and to seek relief in the courts.

Aplt.’s App., Vol. II, at 335 (Pl.’s Emergency Mot. for a TRO & Req. for Hr’g, filed Feb.

27, 2023). Mr. King also “move[d] th[e] . . . Court to convene an emergency hearing on

th[e] injunction [request].” Id. at 355.

On April 13, 2023, the district court denied Mr. King’s motion for a TRO on the

basis that Mr. King had failed to exhaust his administrative remedies. On May 5, 2023,

Mr. King filed an unopposed motion, “request[ing] that the Court clarify whether or not

the Court intended the Order . . . to be a final order with respect to the underlying petition

seeking a writ of Habeas Corpus.” Aplt.’s App., Vol. III, at 768 (Pet’r’s Unopposed Mot.

to Clarify April 13, 2023 Order, filed May 5, 2023). The district court issued a clarifying

order on May 10, 2023, confirming that the April 13 order was intended to be a final

3 Appellate Case: 23-1201 Document: 010111018764 Date Filed: 03/19/2024 Page: 4

order with respect to the underlying habeas petition, and formally denied Mr. King’s

habeas petition for the same reason it denied the TRO motion. Mr. King timely appealed.

B

On January 12, 2024, Mr. King filed his custody status questionnaire with this

Court and indicated that his custody status was “Conditional release; Subject of this

appeal 2241 habeas regarding the execution of Mr. King’s sentence.” Custody Status

Questionnaire, No. 23-1201, at 1 (10th Cir., filed Jan. 12, 2024). Further, both parties’

briefing on the merits noted that Mr. King’s expected release date was February 23, 2024.

See Aplt.’s Opening Br. at 16; Aplee.’s Resp. Br. at 5.

On February 26, 2024, this Court ordered supplemental briefing on whether

Mr. King’s appeal was moot in light of his release from custody on February 23, 2024.

See Order, No. 23-1201, at 1 (10th Cir., filed Feb. 26, 2024). Both parties submitted their

supplemental briefing on March 4, 2024. See Aplt.’s Suppl. Br. at 10; Aplee.’s Suppl.

Br. at 3. The government asserts that Mr. King’s release from prison has mooted his

appeal. See Aplee.’s Suppl. Br. at 1. However, Mr. King asserts “that this matter is not

moot.” Aplt.’s Suppl. Br. at 1.

II

The federal writ of habeas corpus “shall not extend to a prisoner unless . . . [h]e is

in custody in violation of the Constitution or laws . . . of the United States.” 28 U.S.C.

§ 2241(c)(3). Although Mr. King is no longer in prison, the “in custody” requirement of

§ 2241 is satisfied because he filed his habeas application while he was incarcerated. See

Spencer v. Kemna, 523 U.S. 1, 7 (1998); Riley v. INS, 310 F.3d 1253, 1256 (10th Cir.

4 Appellate Case: 23-1201 Document: 010111018764 Date Filed: 03/19/2024 Page: 5

2002). “The more substantial question, however, is whether [Mr. King’s] subsequent

release cause[s] the petition to be moot because it no longer present[s] a case or

controversy under Article III, § 2, of the Constitution.” Spencer, 523 U.S. at 7.

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