Morales v. Rardin

Background

Vidal Licea Morales, who represented himself, filed two petitions under 28 U.S.C. § 2241. These petitions asked the court to review sanctions imposed after disciplinary hearings concerning alleged violations of Bureau of Prisons rules in April and May 2023. The sanctions included the loss of 82 days of good-time credits, the loss of 150 days of non-vested good-time credits, disciplinary segregation, property impoundment, and loss of other privileges.

Morales alleged several defects in the disciplinary process. He asserted, among other things, that the Bureau of Prisons denied him the opportunity to call witnesses, that the hearing officer was not impartial, and that the evidence was insufficient. He also raised claims under the rule requiring agencies to follow their own regulations, the rule announced in Miranda v. Arizona, the Constitution’s Non-Delegation Clause, and the Appointments Clause.

After Morales filed the petitions, the Bureau of Prisons vacated both disciplinary findings and sent the alleged violations back for rehearing. It restored 232 days of good-time credit. A sworn declaration stated that the rehearings would occur before an adjudicator properly appointed by the Attorney General and that any disciplinary segregation or privilege restrictions imposed after rehearing would count as already served.

Court’s Analysis

The respondent moved to dismiss the petitions as moot and contrary to law. Mootness means that an event has left the court unable to provide meaningful relief, so there is no longer an ongoing legal dispute that the court can decide.

The court held that vacating the disciplinary sanctions and restoring the lost good-time credits eliminated any effect those sanctions had on the length of Morales’s confinement. The court therefore could no longer grant habeas relief based on those sanctions. It also concluded that the Appointments Clause claim was moot because Morales had received the remedy that a successful claim would have required: a new hearing before a properly appointed official.

Morales argued that the voluntary-cessation exception should allow his Non-Delegation Clause claim to continue. That exception can apply when a party voluntarily stops the challenged conduct but remains free to resume it. The court rejected the argument because it found that the Non-Delegation Clause claim lacked merit.

The court explained that Congress may delegate authority if it provides an “intelligible principle” to guide the delegate’s actions. It concluded that federal statutes directing the Bureau of Prisons to provide for prisoner discipline and governing the awarding or reduction of good-time and earned-time credits supplied sufficient guidance. The court therefore found that the statutes did not violate the Non-Delegation Clause.

Disposition

Judge Jeffrey M. Bryan granted the respondent’s motions to dismiss. The order dismissed without prejudice as moot Morales’s claims asserting violations of Accardi, Miranda, and the Appointments Clause. It dismissed with prejudice Morales’s claims asserting violations of the Non-Delegation Clause. The order directed that judgment be entered.