MacDermott v. Federal Bureau of Prisons
- Jeffrey Bryan
- 0:24-cv-01984
- U.S. District Court · District of Minnesota
- 2
In MacDermott v. Federal Bureau of Prisons, Judge Bryan dismissed the case without prejudice because MacDermott's transfer to home confinement made his claims moot.
Self-represented federal prisoners or former prisoners who file suit against the Bureau of Prisons while incarcerated and are later transferred to home confinement, potentially rendering their claims moot before the case is resolved.
What happened
In MacDermott v. Federal Bureau of Prisons (Case No. 24-CV-01984), Troy Nicholas MacDermott, a self-represented plaintiff, sued the Federal Bureau of Prisons and its director, Collette S. Peters, in her official capacity. The case was referred to a magistrate judge, who issued a recommendation on May 27, 2025, concluding that MacDermott's transfer to home confinement had rendered his legal claims moot — meaning there was no longer an active dispute for the court to resolve.
Neither MacDermott nor the defendants objected to the magistrate judge's recommendation within the required time period. When no objections are filed, the court reviews the recommendation only for obvious errors. Judge Jeffrey M. Bryan found no clear error in the magistrate judge's analysis.
Judge Bryan adopted the magistrate judge's recommendation in full. The defendants' motion to dismiss was granted on the ground that the court lacked jurisdiction because the case was moot. The amended complaint was dismissed without prejudice, meaning MacDermott is not necessarily barred from raising his claims again if circumstances change.
The detailed version
- MacDermott v. Federal Bureau of Prisons · No. 0:24-cv-01984
- Jeffrey M. Bryan
- July 24, 2025
Background
Plaintiff Troy Nicholas MacDermott, self-represented (meaning he had no attorney), filed suit against the Federal Bureau of Prisons (BOP) and Collette S. Peters in her official capacity as BOP director. The nature of MacDermott's underlying claims is not described in this order, but the case was filed in the District of Minnesota. MacDermott's address of record is Anchorage, Alaska.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R&R) on May 27, 2025. The R&R concluded that the case should be dismissed for lack of subject-matter jurisdiction — the court's legal authority to hear a case — on the ground of mootness. A case becomes moot when events occurring after the lawsuit is filed eliminate the controversy between the parties, leaving nothing for the court to resolve. Here, Magistrate Judge Elkins found that MacDermott's transfer to home confinement rendered his claims moot.
No Objections Filed
Neither party filed objections to the R&R within the time allowed under District of Minnesota Local Rule 72.2(b)(1). When no party objects, the district court reviews the R&R only for "clear error" — a deferential standard under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996)).
Court's Ruling
Judge Bryan found no clear error in the R&R and adopted it in full. The court:
- Adopted the R&R (Doc. No. 51).
- Granted the defendants' Motion to Dismiss (Doc. No. 34) for lack of jurisdiction.
- Dismissed the Amended Complaint (Doc. No. 33) without prejudice.
A dismissal without prejudice means the court is not permanently barring MacDermott from reasserting his claims; he is not foreclosed from refiling if the jurisdictional barrier — mootness — is no longer applicable. Judgment was ordered to be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.