Sampson Lee v. Eric Rardin

• Court: District Court, E.D. Michigan
• Decided: May 18, 2026
• Docket: 2:25-cv-13027
• Status: Unknown

Opinion

EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

SAMPSON LEE,

Plaintiff, Case No. 2:25-cv-13027

v. Honorable Susan K. DeClercq United States District Judge ERIC RARDIN,

Defendant. _____________________________________/

OPINION AND ORDER GRANTING RESPONDENT’S MOTION TO DISMISS (ECF No. 7) AND DISMISSING PETITION (ECF No. 1) AS MOOT

Sampson Lee filed this petition for a writ of habeas corpus under 28 U.S.C. § 2241 while incarcerated at the Federal Correctional Institution in Milan, Michigan (“FCI-Milan”). ECF No. 1. Lee alleges that the Federal Bureau of Prisons (BOP) has failed to properly apply his earned time credits under the First Step Act and the Second Chance Act. He seeks recalculation of his earned time credits and immediate transfer to pre-release custody. Id. at PageID.7. Respondent has moved to dismiss the petition. As explained below, the Court will grant the Respondent’s motion and dismiss Lee’s petition. I. BACKGROUND In 2019, Lee pleaded guilty to coercion or enticement of a minor, in violation of 18 U.S.C. § 2422(a). See United States v. Lee, No. 18-cr-154 (D. N.D.). On October 10, 2019, he was sentenced to 135 months of imprisonment to be followed by five years of supervised release. See id. at ECF No. 52.

In September 2025, Lee filed the present habeas petition. He argues that the BOP has failed to transfer him to pre-release custody because it did not properly calculate the credits to which he claims entitlement under the First Step Act and

Second Chance Act. ECF No. 1 at PageID.6. He asks the Court to order the BOP to recalculate his credits and transfer him to pre-release custody. Id. at PageID.7. Respondent has filed a motion to dismiss, asserting that Lee’s petition is now moot because Lee has been released to a Residential Reentry Management Center in

New York. See ECF No. 7 at PageID.80. Lee has not filed a response. II. LEGAL STANDARD Article III, § 2 of the Constitution confines the judicial power of the federal

courts to actual, ongoing cases or controversies. That limitation means that a litigant “must have suffered, or be threatened with, an actual injury traceable to the defendant and likely to be redressed by a favorable judicial decision.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477 (1990). The case-or-controversy

requirement continues through all stages of a judicial proceeding. Id. “[I]t is not enough that a dispute was very much alive when suit was filed . . . The parties must continue to have a ‘personal stake in the outcome’ of the lawsuit.” Id. (quoting Los

Angeles v. Lyons, 461 U.S. 95, 101 (1983) (additional quotation omitted)). A case becomes moot “when events occur during the pendency of a litigation which render the court unable to grant the requested relief.” Carras v. Williams, 807

F.2d 1286, 1289 (6th Cir. 1986). Federal courts therefore lack jurisdiction to consider a case that has “‘lost its character as a present, live controversy.’” Demis v. Sniezek, 558 F.3d 508, 512 (6th Cir. 2009) (quoting Hall v. Beals, 396 U.S. 45, 48 (1969)). If

issuing a writ of habeas corpus would neither shorten the petitioner’s custody nor yield any collateral consequences, then no live controversy remains for the court to resolve, and the case is moot. See id. at 513. III. DISCUSSION

Lee’s petition no longer presents a justiciable case or controversy because the relief he sought, pre-release custody, has been granted. Id. (holding a federal prisoner’s challenge to a BOP policy preventing his transfer to a community

corrections center, or halfway house, was rendered moot by the prisoner’s release from custody). Additionally, earned time credits may not be used to reduce a term of supervised release. Hargrove v. Healy, 155 F.4th 530, 536 (6th Cir. 2025). So Lee’s release from custody “makes it impossible for [this Court] to grant any effectual

relief.” Id. Thus, because this Court lacks jurisdiction to decide this moot petition it will grant Respondent’s motion to dismiss, ECF No. 7, and dismiss Lee’s petition, ECF No. 1, as moot. IV. CONCLUSION Accordingly, it is ORDERED that Respondent’s Motion to Dismiss, ECF No.

7, is GRANTED. Further, it is ORDERED that Lee’s Petition for a Writ of Habeas Corpus, ECF No. 1, is DISMISSED AS MOOT.

This is a final order and closes the above-captioned case. /s/Susan K. DeClercq SUSAN K. DeCLERCQ United States District Judge Dated: May 18, 2026