Morales v. Rardin

Background

Vidal Licea Morales, who represented himself, was incarcerated at FMC Rochester. After disciplinary hearings in April and May 2023, the Bureau of Prisons found that he had violated rules concerning destruction of an item during a search and possession of a hazardous tool. The sanctions included loss of 82 days of good-time credits, loss of 150 days of non-vested good-time credits, disciplinary segregation, property impoundment, and loss of other privileges.

Morales filed two petitions under 28 U.S.C. § 2241, a procedure used to challenge certain aspects of federal custody. He alleged several constitutional and procedural defects, including denial of the opportunity to call witnesses, lack of an impartial hearing officer, and insufficient evidence. He also asserted claims under the rule requiring agencies to follow their own regulations, the Miranda rule, the Non-Delegation Clause, and the Appointments Clause.

Events After Filing

On November 20, 2024, the Bureau of Prisons vacated the findings from both disciplinary hearings and sent the alleged violations back for rehearing. It restored Morales’s 232 days of good-time credit. The Bureau also stated that the rehearings would occur before an adjudicator appointed by the Attorney General, that the adjudicator would make a fresh decision about the violations and any sanctions, and that any renewed disciplinary-segregation or privilege restrictions would count as already served.

Mootness Ruling

Rardin moved to dismiss the petitions because the issues were moot and the petitions were contrary to law. A matter is moot when events prevent a federal court from providing meaningful relief. The court held that vacating the disciplinary sanctions and restoring the lost good-time credits eliminated any effect on the length of Morales’s confinement. As a result, the court could no longer grant habeas relief and no ongoing dispute remained for the claims affected by those changes.

The court also rejected Morales’s argument that the voluntary-cessation exception kept the case alive. That exception can sometimes allow a court to review a challenged practice after the defendant voluntarily stops it, but the court concluded that the exception did not apply here. The court separately stated that any Appointments Clause claim was moot because Morales had received the remedy that a successful claim would require: a new hearing before a properly appointed official.

Non-Delegation Clause Claim

The Non-Delegation Clause limits Congress’s ability to give its authority to another body without providing an intelligible principle—guidance sufficient to direct how that authority must be used. The court held that the statutes governing the Bureau of Prisons provide adequate guidance. Those statutes direct the Bureau to provide for the discipline of federal prisoners, address good-time credits, and establish requirements and guidelines for reducing credits or other earned rewards after rule violations.

Because Morales cited no authority showing that these statutory provisions lacked sufficient guidance, the court rejected the Non-Delegation Clause claim on the merits.

Disposition

The court granted Rardin’s motions to dismiss in both cases. It dismissed Morales’s Accardi, Miranda, and Appointments Clause claims without prejudice as moot. It dismissed the Non-Delegation Clause claims with prejudice. The order did not state a separate disposition in its numbered ruling for every other deficiency Morales described in the petitions.