Meadows v. Williams et al
Memorandum of Opinion and Order For the reasons set forth herein, the Petition, ECF No. 1 , is dismissed pursuant to Rule 4 of the Rules Governing Habeas Corpus Cases. Judge Benita Y. Pearson on 3/31/2021. (JLG)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
SEAN M. MEADOWS,
WARDEN MARK WILLIAMS,
CASE NO. 4:20-CV-1594
JUDGE BENITA Y. PEARSON
MEMORANDUM OF OPINION
Pro se Petitioner Sean M. Meadows has filed an Emergency Petition for a Writ of Habeas
Corpus under 28 U.S.C. § 2241. ECF No. 1. At the time the Petition was filed, Petitioner was a
federal inmate incarcerated at FCI Elkton. Id. at PageID #: 3. Petitioner is now incarcerated at
Yazoo City USP.1 He seeks immediate release to home confinement due to the purported
COVID-19 outbreak at FCI Elkton. Petitioner alleges that Respondent failed to provide him with
adequate protection from COVID-19 in violation of his rights under the Eighth Amendment.
ECF No. 1.
Promptly after the filing of a habeas corpus petition, a federal district court must
undertake a preliminary review of the petition to determine “[i]f it plainly appears from the
petition and any attached exhibits that the petitioner is not entitled to relief.” Rule 4 of the Rules
Governing Habeas Corpus Cases Under Section 2254 (applicable to petitions under § 2241
See Bureau of Prisons Inmate Locator, bop.gov/inmateloc/ (last visited March
pursuant to Rule 1(b)). If so, the petition must be summarily dismissed. Id.; Day v. McDonough,
547 U.S. 198, 207 (2006).
Upon review, the Court finds that the instant Petition must be dismissed as moot. The
Petition challenges the conditions of Petitioner’s confinement at FCI Elkton, but Petitioner is no
longer confined at that institution. “A habeas claim that does not challenge the validity of a
criminal judgment ordinarily is moot when the condition at issue has abated or the inmate has
been transferred to another facility.” Avery v. Phillips, No. 2:14-CV-01276-STA-egb, 2016 WL
94143, at *4 (W.D. Tenn. Jan. 7, 2016); see also Demis v. Sniezek, 558 F.3d 508, 512-13 (6th
Cir. 2009) (affirming district court’s dismissal of habeas petition as moot when petitioner,
challenging regulations related to inmate transfer to community correctional center, was
transferred to a community correctional center before his petition was adjudicated). Because
Petitioner is no longer subject to the conditions of confinement at FCI Elkton that his Petition
challenges, “no actual injury remains that the Court could redress with a favorable decision.”
Demis, 558 F. 3d at 513.
Accordingly, the Petition, ECF No. 1, is dismissed pursuant to Rule 4 of the Rules
Governing Habeas Corpus Cases.
IT IS SO ORDERED.
March 31, 2021
/s/ Benita Y. Pearson
Benita Y. Pearson
United States District Judge
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