Morales v. Rardin
- Jeffrey Bryan
- 0:24-cv-03366
- U.S. District Court · District of Minnesota
- 4
In Morales v. Rardin, Judge Bryan denied Morales’s two requests to stop new prison disciplinary proceedings because he showed neither likely success nor immediate harm.
Vidal Licea Morales’s requests for emergency relief were denied, allowing the Bureau of Prisons’ contemplated new disciplinary proceedings to remain unblocked by these motions.
What happened
Morales v. Rardin involves two habeas cases challenging prison disciplinary proceedings that caused Morales to lose about eight months of good-time credits. The Bureau of Prisons later vacated those proceedings and restored the credits, at least temporarily, while planning new proceedings.
Morales asked the court to immediately stop the planned proceedings, arguing that they would again violate his constitutional rights. The court evaluated his requests under the four-factor test for temporary restraining orders, including likely success and immediate, irreparable harm.
Judge Jeffrey M. Bryan denied both requests. He ruled that federal law gives the Bureau of Prisons authority to create disciplinary rules and withhold good-time credits, and he found no immediate harm supporting emergency relief because Morales was not scheduled for release until 2035.
The detailed version
- Morales v. Rardin · No. 0:24-cv-03366
- Jeffrey M. Bryan
- Dec. 26, 2024
Background
Vidal Licea Morales filed two habeas petitions challenging separate federal prison disciplinary proceedings. He alleged, among other things, that the Bureau of Prisons violated his due-process rights and his protection against self-incrimination, failed to follow its own disciplinary procedures, used an unconstitutionally appointed hearing officer, and lacked authority from Congress to create rules disciplining prisoners. The proceedings had resulted in the loss of about eight months of good-time credits.
The Government moved to dismiss the habeas petitions after the disciplinary proceedings were vacated and Morales’s good-time credits were restored, at least temporarily. The Bureau of Prisons intended to conduct new disciplinary proceedings. Morales acknowledged that the earlier proceedings and resulting loss of credits had been vacated, but he asked the court to stop the contemplated new proceedings.
Temporary Restraining Order Standard
A temporary restraining order is an extraordinary form of emergency relief. The person requesting it must establish four factors: likely irreparable harm without the order, the balance between that harm and harm to the Government, a likelihood of success on the underlying claims, and the public interest. The court identified irreparable harm and likelihood of success as the two most important factors.
Court’s Analysis
The court rejected Morales’s argument that the Bureau of Prisons lacked authority to conduct disciplinary proceedings. It held that clear federal law, specifically 28 U.S.C. § 3624(b)(1), gives the Bureau of Prisons authority to establish disciplinary rules and withhold good-time credits from prisoners found to have violated them. The court therefore found that Morales had not shown a likelihood of success on his claims.
The court also found no sufficient threat of irreparable harm. Even after his credits were restored, Morales was not scheduled for release from Bureau of Prisons custody until 2035, and he offered no reason why an immediate temporary restraining order was necessary. Because Morales failed to establish the two most important factors, the court did not address the other two factors.
Disposition
The court denied Morales’s motion for a temporary restraining order in Case No. 24-CV-03121 and denied his motion for a temporary restraining order in Case No. 24-CV-03366. The order did not decide the Government’s motions to dismiss the underlying habeas petitions.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.