Goggans v. Jamison

Background

Lacy J. Goggans, representing himself, filed a petition for a writ of habeas corpus, a court request concerning the lawfulness or conditions of custody. He asked to be transferred from the Federal Correctional Institution in Otisville, New York, to prerelease custody under the First Step Act of 2018.

The Bureau of Prisons transferred Goggans to prerelease custody in a residential reentry center on July 5, 2023. On August 22, 2023, it released him from the reentry center to begin his three-year term of supervised release. Goggans alleged that he had earned 510 First Step Act credits. A Bureau of Prisons representative stated that Goggans had earned 340 credit days toward early release, explaining that he was not participating in the credit program during some periods.

Court’s Analysis

The court treated the petition as moot because Goggans had already received the transfer he originally requested. A matter is moot when the court can no longer provide effective relief.

The court also considered whether Goggans’s petition could be understood as asking to use any remaining First Step Act credits to reduce his supervised-release term. It concluded that the statute does not permit that use of credits. The court relied on the statutory language providing that credits are applied toward time in prerelease custody or supervised release, and agreed with an analysis from another federal district court that the statute allows credits to move a person closer to placement in supervised release, not to shorten an already imposed supervised-release term.

Disposition

Judge Gregory H. Woods denied Goggans’s petition as moot because Goggans had been released and the court could grant him no further relief based on any remaining First Step Act credits. The court directed the clerk to enter judgment for the respondent, close the case, and mail Goggans a copy of the decision.