Keitt v. United States
- Vernon Broderick
- 1:22-cv-09954
- U.S. District Court · Southern District of New York
- 3
In Keitt v. United States, Judge Broderick denied Keitt’s petition as moot and dismissed the case after his release.
Jayvon Keitt, who represented himself, and the United States. The ruling ended Keitt’s petition seeking First Step Act time credits because the court found it moot.
What happened
In Keitt v. United States, Jayvon Keitt asked the court to order the Bureau of Prisons to award him sentence-reduction credits under the First Step Act. He filed the petition while he was in federal custody and represented himself.
Keitt was later released from custody, and his supervised release was terminated. The government argued that the petition was moot because Keitt was no longer incarcerated or on supervised release, and Keitt did not respond to the court’s request for his position.
Judge Broderick ruled that Keitt had received all the relief he sought, so the petition was moot. The court denied the petition as moot, dismissed the case, denied fee-free appeal status, and directed the clerk to close the case.
The detailed version
- Keitt v. United States · No. 1:22-cv-09954
- Vernon Broderick
- Apr. 17, 2025
Background
Jayvon Keitt, representing himself, filed a petition under 28 U.S.C. § 2241, a law allowing a federal prisoner to challenge certain aspects of custody. Keitt alleged that the Federal Bureau of Prisons improperly refused to award him time credits under the First Step Act. He asked the court to order the Bureau of Prisons to grant those credits and reduce his sentence.
Events After Filing
Keitt was later released from Bureau of Prisons custody and began supervised release. He was arrested for violating the conditions of supervised release on October 28, 2024. After admitting to certain violations, he was sentenced to time served. The judgment did not impose an additional period of supervised release, and the government reported that his supervised release ended on December 9, 2024.
Magistrate Judge Gary Stein directed the parties to explain whether the petition had become moot. The government stated that Keitt was no longer in custody or on supervised release and argued that the petition was moot. Keitt did not submit a response.
Court’s Analysis
A case is moot when the court can no longer provide the requested relief or that relief is no longer needed. A federal court lacks authority to decide a moot case. Judge Broderick found that Keitt was no longer incarcerated and was no longer on supervised release. As a result, the court concluded that Keitt had received all the relief sought in his petition.
Ruling
The court denied the Petition as moot. It then dismissed the case, certified that any appeal would not be taken in good faith, denied Keitt permission to appeal without paying the filing fees, directed the clerk to enter judgment, and closed the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.