Morley v. Trump
- Katherine Menendez
- 0:25-cv-01580
- U.S. District Court · District of Minnesota
- 3
In Morley v. Trump, Judge Menendez denied the habeas petition and related motions as moot and dismissed the action without prejudice for lack of jurisdiction.
Raymond James Morley’s petition and related requests were denied as moot after immigration authorities removed him to the Bahamas; the action was dismissed without prejudice for lack of jurisdiction.
What happened
In Morley v. Trump, Raymond James Morley challenged his immigration detention, conditions at the Sherburne County Jail, and the decision ordering his removal. He also asked to proceed without paying filing fees and requested appointed counsel.
Before Morley received a magistrate judge’s recommendation, immigration authorities removed him to the Bahamas. The court ruled that his removal left it unable to provide effective relief, making the petition moot, and found no exception to that rule.
Judge Katherine Menendez denied the petition, the application to proceed without paying filing fees, and the request for appointed counsel as moot. She also dismissed the action without prejudice for lack of jurisdiction.
The detailed version
- Morley v. Trump · No. 0:25-cv-01580
- Katherine Menendez
- June 25, 2025
Background
Raymond James Morley filed a petition under 28 U.S.C. § 2241 seeking court relief from his immigration detention. He alleged that his detention was improper while his immigration case was resolved, described abusive conditions at the Sherburne County Jail, and challenged the decision ordering his removal. He also applied to proceed without paying filing fees and moved for appointed counsel.
Morley was being held by federal authorities at the Sherburne County Jail in Elk River, Minnesota. On May 27, 2025, before he received the magistrate judge’s Report and Recommendation, U.S. Immigration and Customs Enforcement removed him from the United States to the Bahamas. The magistrate judge’s recommendation had concluded that the petition should be denied for lack of jurisdiction.
Court’s Analysis
Judge Menendez explained that Article III of the Constitution requires an ongoing case or controversy. If circumstances change so that a court can no longer provide effective relief, the case becomes moot. In a detention-related petition, the petitioner’s release or removal ordinarily prevents the court from ordering the requested relief.
The court found that Morley’s removal made the petition moot because he could no longer receive effective relief from the court. The court also found that the record did not show that any recognized exception to mootness applied, including an issue capable of repetition but likely to evade review, continuing collateral injuries, or a properly certified class action.
Disposition
The court ordered that:
- Morley’s petition for a writ of habeas corpus was DENIED as moot.
- His application to proceed without paying filing fees and his motion for appointed counsel were DENIED as moot.
- The action was DISMISSED WITHOUT PREJUDICE for lack of jurisdiction.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.