Renouard v. Eischen
- Eric Tostrud
- 0:25-cv-01569
- U.S. District Court · District of Minnesota
- 4
In Renouard v. Eischen, Judge Docherty recommends denying the petition as moot and dismissing the action without prejudice.
The recommendation concerns Jacob Parker Renouard’s petition challenging the Bureau of Prisons’ calculation of his First Step Act time credits. It proposes denying the petition as moot and dismissing the action without prejudice; the report and recommendation was not a final district-court order.
What happened
In Jacob Parker Renouard v. B. Eischen, FPC-Duluth Warden, Renouard argued that the Bureau of Prisons failed to apply 82 days of First Step Act time credits to his sentence.
Renouard was released from Bureau of Prisons custody on August 25, 2025, while his petition was pending. The court concluded that his release meant it could no longer provide the requested relief and that no exception to mootness applied.
Judge John F. Docherty recommended denying Renouard’s petition as moot and dismissing the action without prejudice for lack of authority to decide the case. The recommendation was not a final order, and the parties could file objections.
The detailed version
- Renouard v. Eischen · No. 0:25-cv-01569
- Eric Tostrud
- Feb. 20, 2026
Background
Jacob Parker Renouard filed a petition under 28 U.S.C. § 2241 challenging the Bureau of Prisons’ calculation of his First Step Act time credits. He argued that the Bureau of Prisons improperly excluded periods after sentencing and before his arrival at his designated institution while he was being transferred between Bureau of Prisons institutions. He asserted that crediting those periods would make 82 additional days available to apply to his statutory sentence.
Renouard filed the petition on April 10, 2025, and the court received it on April 17, 2025. The respondent’s response stated that Renouard’s projected release date had moved to November 7, 2025, based on his continued accumulation of time credits. A later declaration stated that Renouard was released from Bureau of Prisons custody on August 25, 2025, under the First Step Act.
Court’s Analysis
The court explained that the Constitution limits federal courts to actual, ongoing cases or controversies. A case becomes moot when changed circumstances mean the court can no longer provide effective relief. Because Renouard had been released, the court concluded that it could no longer grant the relief he sought.
The court also concluded that no exception to mootness applied. It found that Renouard had no legally recognizable continuing injury and that the issue was not likely to happen again while avoiding review. The court stated that any future return to custody would involve different facts. Because the matter was moot, the court said it lacked authority to decide the petition’s underlying merits.
Recommendation and Procedure
Judge John F. Docherty recommended that Renouard’s petition be denied as moot and that the action be dismissed without prejudice for lack of subject matter jurisdiction. The report and recommendation stated that it was not a final order or judgment and was not directly appealable. It explained that a party could file specific written objections within 14 days after being served with the report and recommendation.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.