Gorrio v. Dauphin County Prison, 1:22-cv-00703

Petitioner Michael Gorrio, then incarcerated at Dauphin County Prison (DCP), filed a pro se § 2241 petition asserting constitutional violations arising from placement in administrative segregation beginning September 8, 2021.
A disciplinary report found Gorrio guilty of fighting and imposed a 30-day lock-in with a release date of October 17, 2021, but Gorrio alleges he was kept in segregation for 93 days without a proper disciplinary hearing or explanation.
Gorrio also alleges physical and sexual assaults by correctional officers during a strip search, destruction of his legal and personal property, and that prison officials ceased responding to his administrative remedies.
He sought an evidentiary hearing and immediate return to general population (release from administrative segregation) as relief.
The Court granted leave to proceed in forma pauperis, gave preliminary consideration under Rule 4 of the Rules Governing § 2254 cases (applicable to § 2241), and found the petition subject to dismissal for lack of jurisdiction.
On August 3, 2022, Gorrio was transferred to SCI Camp Hill; the Court held his requested relief against DCP moot and dismissed the § 2241 petition without prejudice to a civil rights action; a certificate of appealability was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gorrio's claims about disciplinary process, assaults, and property destruction can proceed in a § 2241 habeas petition	Gorrio seeks release from administrative segregation and alleges due process, Fourth, Eighth, Fifth, and Fourteenth Amendment violations tied to his confinement conditions	DCP (and the Court) contend these are challenges to conditions of confinement, not to the fact or duration of custody, so they are not proper in habeas	Court: Claims challenge conditions of confinement, not the validity/duration of sentence; not cognizable in habeas and must be pursued as a civil rights action
Whether the petition is moot after Gorrio's transfer from DCP to SCI Camp Hill	Gorrio requested return to general population at DCP	Transfer eliminates Court's ability to order the specific relief against DCP	Court: Transfer moots request for relief against DCP; dismissal required
Whether to issue a certificate of appealability (COA)	Gorrio seeks appellate review	No substantial showing of denial of a constitutional right	Court: COA denied

Muhammad v. Close, 540 U.S. 749 (2004) (distinguishes habeas challenges to conviction/duration from claims about conditions of confinement)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas available to attack fact or duration of confinement; conditions claims belong in civil rights suits)
Leamer v. Fauver, 288 F.3d 532 (3d Cir. 2002) (challenge that would not alter sentence should proceed as civil rights action)
Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690 (3d Cir. 1996) (mootness doctrine requires dismissal when intervening developments eliminate a litigant's personal stake)
Khodara Envtl., Inc. v. Beckman, 237 F.3d 186 (3d Cir. 2001) (federal courts confined to live cases or controversies)
Miller-El v. Cockrell, 537 U.S. 322 (2003) (standard for making a substantial showing of the denial of a constitutional right for COA)
Slack v. McDaniel, 529 U.S. 473 (2000) (COA requires substantial showing; standard for evaluating COA requests)