Edwards v. Holder et al
MEMORANDUM OPINION. Because there is no longer any relief that can be granted to Mr. Edwards, his petition is due to be dismissed as moot.Signed by Judge Madeline Hughes Haikala on 1/29/2016. (KMG)
2016 Jan-29 PM 05:45
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
LORETTA LYNCH,1 et al.,
Case Number: 4:14-cv-00876-MHH-JHE
Petitioner Floyd Edwards 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, Mr. Edwards, a native of the Marshall
Islands, was incarcerated at the Etowah County Detention Center, in the custody of the Bureau of
Immigration and Customs Enforcement (“ICE”). In his petition, Mr. Edwards alleged that he
was being illegally detained by ICE. On January 4, 2016, ICE released Mr. Edwards from
custody; Mr. Edwards was deported from the United States. (Doc. 34, 34-1). Respondents have
filed a motion to dismiss the action as moot because Mr. Edwards is no longer in ICE custody.
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.
Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Eric H. Holder, Jr.’s
successor as United States Attorney General, Loretta Lynch, is automatically substituted as a
respondent in this action.
Ashcroft, 323 F.3d 906, 913 (11th Cir. 2003) (citations omitted). Mr. Edwards’s release from
ICE custody rendered his petition moot.
Because Mr. Edwards’s petition is moot, the Court must dismiss the petition unless an
exception to the mootness doctrine applies. There are two exceptions to the mootness doctrine:
(1) collateral consequences and (2) “capable of repetition yet evading review.” Carafas v.
LaVallee, 391 U.S. 234, 237 (1968); Murphy v. Hunt, 455 U.S. 478, 482 (1982). Neither
exception applies here. The collateral consequences exception does not apply because there are
no “disabilities or burdens which may flow” from the custody that Mr. Edwards challenges. See
Carafas, 391 U.S. at 237. The exception for events “capable of repetition, yet evading review”
does not apply here either. Mr. Edwards has been released 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 (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 there is no longer any relief that can be granted to Mr.
Edwards, his petition is due to be dismissed as moot.
Based on the foregoing, the Respondents’ motion to dismiss, (Doc. 34), is GRANTED.
A separate order will be entered.
DONE and ORDERED this January 29, 2016.
MADELINE HUGHES HAIKALA
UNITED STATES DISTRICT JUDGE
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?