Medrano v. Entrekin
MEMORANDUM OPINION. Signed by Judge Virginia Emerson Hopkins on 5/12/2016. (JLC)
2016 May-12 PM 04:17
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
PITERSON R. MARTINEZ
) Case No. 4:15-cv-01477-VEH-JHE
On August 27, 2015, Petitioner Piterson R. Martinez Medrano (“Medrano”)
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, Medrano, a native of Dominican Republic, was
incarcerated at the Etowah County Detention Center, in the custody of the Bureau
of Immigration and Customs Enforcement (“ICE”).
In his petition, Medrano
alleged that he was being illegally detained by ICE pending his deportation to the
Dominican Republic. On April 5, 2016, Medrano was deported from the United
States. (Doc. 7, 7-1). Respondents have filed a motion to dismiss the action as
moot, since Medrano is no longer in ICE custody. (Doc. 7). For the reasons stated
below, Respondents’ motion will be granted and the action be 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). Medrano’s release from ICE custody
rendered his petition moot.
The relief Medrano seeks in his petition is to be released from ICE custody.
Because he is no longer in ICE custody, his petition has been rendered moot,
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 Medrano challenges. See Carafas,
391 U.S. at 237. The exception for events “capable of repetition, yet evading
review” does not apply here either. Petitioner 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
Medrano, his petition is due to be dismissed as moot.
Based on the foregoing, the Respondents’ motion to dismiss, (doc. 7), is
GRANTED. A separate order will be entered.
DONE this 12th day of May, 2016.
VIRGINIA EMERSON HOPKINS
United States District Judge
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