Morales v. Rardin

Background

Vidal Licea Morales, who is detained at the Federal Medical Center in Rochester, Minnesota, filed two petitions challenging separate prison disciplinary proceedings. Together, those proceedings had resulted in the loss of about eight months of good-time credits. His petitions raised claims concerning due process, the right against self-incrimination, Bureau of Prisons procedures, the appointment of the hearing officer, and the Bureau’s authority to create disciplinary rules.

The government separately moved to dismiss both petitions, arguing that later events had made Morales’s claims moot. The disciplinary proceedings had been vacated, and his good-time credits had been restored, at least temporarily. The Bureau of Prisons planned to conduct new disciplinary proceedings. Morales then filed a motion for a temporary restraining order in each case, asking the court to immediately stop those contemplated proceedings. The order addressed only the temporary restraining-order motions.

Legal 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 the 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 the disciplinary hearings. It cited 28 U.S.C. § 3624(b)(1), which expressly authorizes the Bureau to establish disciplinary rules and withhold good-time credits from prisoners found to have violated those rules. The court therefore found that Morales had not shown a likelihood of success on his claims.

The court also found that Morales had not shown irreparable harm. Although his credits had been restored, he was not scheduled for release from Bureau of Prisons custody until 2035. Morales did not explain why the court should provide immediate, extraordinary relief under those circumstances. Because these two factors strongly weighed against relief, the court did not address the two remaining 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 state a ruling on the government’s separate motions to dismiss the habeas petitions.