Craft v. Eischen
- Katherine Menendez
- 0:22-cv-01897
- U.S. District Court · District of Minnesota
- 2
In Craft v. Eischen, Judge Menendez denied Craft’s federal petition as moot and dismissed the case without prejudice after he received the requested relief.
Charles B. Craft, whose petition was denied as moot; and B. Eischen, the named respondent.
What happened
Craft v. Eischen concerned Charles B. Craft’s petition under federal law seeking relief related to his sentence. A magistrate judge found that the Bureau of Prisons had applied First Step Act credits to Craft’s sentence and transferred him to home confinement, giving him the relief he requested.
Because Craft had already received that relief, the magistrate judge concluded that there was no longer a live dispute for the court to decide. No one objected to the recommendation, and the court found no clear error.
Judge Katherine Menendez accepted the recommendation, denied the petition as moot, and dismissed the case without prejudice. The order did not decide the petition’s underlying merits.
The detailed version
- Craft v. Eischen · No. 0:22-cv-01897
- Katherine Menendez
- May 15, 2023
Background
Charles B. Craft petitioned under 28 U.S.C. § 2241 for a court order concerning his sentence. Magistrate Judge Tony L. Leung recommended denying the petition and dismissing the case without prejudice. The recommendation stated that the Bureau of Prisons had applied First Step Act credits to Craft’s sentence and transferred him from the Federal Prison Camp in Duluth to home confinement. Because Craft had received the relief he requested, the recommendation concluded that no live case or controversy remained.
Review of the Recommendation
No objections were filed to the magistrate judge’s Report and Recommendation. Under the court’s stated procedure, the district court therefore reviewed the recommendation for clear error. After reviewing the recommendation and the entire record, the court found no error. The recommendation also concluded that no exception to the rule requiring a live dispute applied.
Ruling
Judge Katherine Menendez accepted the Report and Recommendation. The court expressly ruled that the petition for a writ of habeas corpus under 28 U.S.C. § 2241 was DENIED AS MOOT and that the matter was DISMISSED WITHOUT PREJUDICE. “Moot” means that the court no longer had a live dispute to resolve because the requested relief had already been provided. The order did not reach the underlying merits of Craft’s petition.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.