Pratt v. Dunn
MEMORANDUM OPINION. Signed by Judge L Scott Coogler on 4/12/2016. (PSM)
2016 Apr-12 PM 03:03
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
JEFFERSON S. DUNN, Commissioner of )
the Alabama Department of Corrections,
This is a habeas corpus case filed, through counsel, by Charles Pratt, an Alabama state
prisoner, pursuant to 28 U.S.C. § 2254. (Doc. 1). Pratt’s petition seeks relief under Miller v.
Alabama, 132 S. Ct. 2455 (2012), and Montgomery v. Louisiana, 135 S. Ct. 1546 (2015), arguing that
his constitutional rights were violated because he was sentenced to life imprisonment without the
possibility of parole for a homicide committed before age 18, without being given an individualized
sentencing hearing to determine if he should be eligible for parole. (Doc. 1). Pratt’s counsel,
however, has now informed the court that Pratt died on February 18, 2016. (Doc. 7). That renders
this habeas action moot. See Bruno v. Secretary, Fla. DOC, 700 F.3d 445 (11th Cir. 2012). A
separate final order of dismissal will be entered.
Done this 12th day of April 2016.
L. Scott Coogler
United States District Judge
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