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Booker v. Greenville FCI
3:24-cv-02410
| S.D. Ill. | Jul 17, 2025
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Background

  • Edward Booker filed a pro se habeas petition under 28 U.S.C. § 2241 seeking application of credit to his sentence—specifically, time earned under the First Step Act and Second Chance Act.
  • At the time of filing, Booker was incarcerated at FCI Greenville; he requested, among other relief, immediate placement in a Residential Reentry Center (RRC).
  • After the petition, Booker was transferred to an RRC and later granted executive clemency, resulting in his release from the BOP and commencement of a six-year supervised release term.
  • The respondent (Lillard) moved to dismiss the petition as moot, arguing that Booker had received the relief sought (RRC placement).
  • Booker responded that the petition was not moot, as he had not received all the earned time credit he claimed was due under federal statutes.
  • The court was tasked with determining whether Booker's petition remained a live controversy after his transfer and release.

Issues

Issue Booker's Argument Lillard's Argument Held
Is the habeas petition moot due to Booker's transfer to an RRC and later release? Not moot; he did not receive all time credit and benefit under the First Step Act and Second Chance Act. Moot; Booker received RRC placement and release, so no remaining relief to award. Not moot; Booker could benefit from additional credit on supervised release.

Key Cases Cited

  • A.M. v. Butler, 360 F.3d 787 (7th Cir. 2004) (explaining the Article III requirement for live cases or controversies)
  • Pope v. Perdue, 889 F.3d 410 (7th Cir. 2018) (burden on party asserting mootness; case not moot if petitioner could receive any potential benefit)
  • Phifer v. Clark, 115 F.3d 496 (7th Cir. 1997) (release from custody does not automatically moot a § 2241 petition)
  • United States v. Trotter, 270 F.3d 1150 (7th Cir. 2001) (challenge to sentence computation by those on supervised release may remain live)
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Case Details

Case Name: Booker v. Greenville FCI
Court Name: District Court, S.D. Illinois
Date Published: Jul 17, 2025
Docket Number: 3:24-cv-02410
Court Abbreviation: S.D. Ill.