Rodriguez Guzman v. Holder et al
MEMORANDUM OPINION Signed by Chief Judge Karon O Bowdre on 2/26/15. (SAC )
2015 Feb-26 AM 11:55
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
JOSE ESTEBAN RODRIGUEZ GUZMAN,
ERIC H. HOLDER, JR., et al.,
) Case No. 4:14-cv-00853-KOB-JHE
On May 7, 2014, Petitioner Jose Esteban Rodriguez Guzman, a native of Guatemala,
filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. (Doc. 1). At the time
he filed his petition, Petitioner was incarcerated at the Etowah County Detention Center, in the
custody of the Bureau of Immigration and Customs Enforcement. Petitioner alleged that he was
being illegally detained by ICE pending his deportation to Guatemala. On November 25, 2014,
ICE released Petitioner from custody. (Docs. 7 & 7-1). Respondents have filed a motion to
dismiss the action as moot because Petitioner is no longer in ICE custody. (Doc. 7). For the
reasons stated below, the court finds that Respondents’ motion is du to be granted and the action
DISMISSED AS MOOT.
Article III of the Constitution limits the jurisdiction of federal courts to the consideration
of “cases or controversies.” U.S. CONST. art. III, § 2. The doctrine of mootness is derived from
this limitation because “an action that is moot cannot be characterized as an active case or
controversy.” Adler v. Duval Cnty. Sch. Bd., 112 F.3d 1475, 1477 (11th Cir. 1997). A case is
moot and must be dismissed if the court can no longer provide “meaningful relief.” Nyaga v.
Ashcroft, 323 F.3d 906, 913 (11th Cir. 2003) (citations omitted). Petitioner’s release from ICE
custody rendered his petition moot.
The relief Petitioner sought was to be released from ICE custody. Because Petitioner is
no longer in ICE custody, his petition has been rendered moot, unless an exception to the
mootness doctrine applies. Two exceptions to the mootness doctrine include (1) collateral
consequences and (2) “capable of repetition yet evading review.” Carafas v. LaVallee, 391 U.S.
234, 237, 88 S. Ct. 1556, 1559 (1968); Murphy v. Hunt, 455 U.S. 478, 482, 102 S. Ct. 1181,
1183-84 (1982). Neither exception applies here.
The collateral consequences exception does not apply because Petitioner has shown no
“disabilities or burdens which may flow” from the custody that Petitioner challenges. See
Carafas, 391 U.S. at 237, 88 S. Ct. at 1559. The exception for events “capable of repetition, yet
evading review” also does not apply. ICE has released Petitioner from custody, and the potential
circumstances of this case happening again are too speculative to create an actual controversy
sufficient to support a claim for relief. See Weinstein v. Bradford, 423 U.S. 147, 149, 96 S. Ct.
347, 348-49 (1975) (holding that the “capable of repetition, yet evading review” exception
applies when (1) the challenged action is too short in duration to be fully litigated prior to its
cessation or expiration, and (2) there is a reasonable expectation that the same complaining party
would be subjected to the same action again.). Because no relief remains that the court can grant
to Petitioner, his petition is due to be dismissed as moot.
Based on the foregoing, the Respondents’ motion to dismiss, (doc. 7), is due to be
The court will enter a separate Order in conformity with this Memorandum Opinion.
DONE and ORDERED this 26th day of February, 2015.
KARON OWEN BOWDRE
CHIEF UNITED STATES DISTRICT JUDGE
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