Huey v. United States
- Paul Magnuson
- 0:20-cv-01538
- U.S. District Court · District of Minnesota
- 2
In Huey v. United States, Judge Magnuson adopted the recommendation, denied the habeas petition as moot, and dismissed the matter without prejudice.
Taylor R. Huey’s § 2241 petition was denied as moot after his release from custody. Michelle Starr, identified as the proper warden-respondent, replaced the United States in the case.
What happened
In Huey v. United States, Taylor R. Huey challenged his custody under a federal law allowing people to ask a court to review their detention. A magistrate judge recommended denying the petition as moot because Huey had been released.
No party objected to that recommendation, and the objection period ended. The district court reviewed the recommendation for clear error and found none.
Judge Magnuson adopted the recommendation, denied the petition as moot, and dismissed the matter without prejudice. The court explained that the warden, Michelle Starr, was the proper respondent and had replaced the United States in the case.
The detailed version
- Huey v. United States · No. 0:20-cv-01538
- Paul Magnuson
- May 7, 2021
Background
Taylor R. Huey filed a petition under 28 U.S.C. § 2241, a federal procedure for challenging a person’s custody. The petition initially named the United States as the respondent. The court noted that the warden of the institution where the person is incarcerated is the proper respondent in a § 2241 case, so Michelle Starr was automatically substituted under Federal Rule of Civil Procedure 25(d).
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on April 19, 2021. It recommended that the petition be denied as moot because Huey had been released from custody. No party objected, and the deadline for objections passed.
Court’s Analysis
Because no party objected, the district court reviewed the Report and Recommendation for clear error rather than conducting a de novo review. The court reviewed the recommendation and found no error, clear or otherwise, in the magistrate judge’s reasoning.
Disposition
The court adopted the Report and Recommendation. It denied the petition as moot and dismissed the matter without prejudice. The court ordered judgment to be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.