Skountzos v. Federal Bureau of Prisons FCI Otisville Satellite Camp

Background

Emmanuel Skountzos filed a petition under 28 U.S.C. § 2241, a procedure that allows a federal prisoner to challenge the execution of a sentence. He had pleaded guilty to tax evasion for the 2015 tax year and had received a 60-day prison sentence followed by three years of supervised release.

At the time he filed the petition, Skountzos was serving his sentence at Federal Correctional Institution Otisville and was scheduled for release on May 8, 2024. He claimed that the Bureau of Prisons had withheld ten days of credits he was entitled to receive under the First Step Act of 2018. He asked for the credits and immediate release.

Government’s response and release

The government reported that a computer-system error had caused the ten credits to be withheld. It stated that the error was corrected on May 3, 2024, and that applying the credits made Skountzos eligible for release. Skountzos was released that day, five days before his scheduled release date, and began supervised release.

Court’s reasoning

The court explained that a case becomes moot when there is no longer a live dispute that a court can resolve. A person released from custody must generally show a concrete, continuing injury beyond the ended incarceration to keep a sentence-execution challenge alive.

Skountzos challenged only the calculation of his prison term. He did not challenge the underlying sentence or seek to change his supervised-release term. Because he had been released and had received the relief he requested, and because he had not shown a continuing injury from the credit calculation, the court concluded that there was no remaining case or controversy. The court stated that the case therefore had to be dismissed for lack of jurisdiction.

Disposition

The court denied Skountzos’s request for relief under Section 2241 as moot. It directed the clerk to terminate the petition and close the case.