(HC) Henry v. Warden of USP Atwater, 1:24-cv-01578

Petitioner Drew Joseph Henry, a federal prisoner, filed a habeas petition under 28 U.S.C. § 2241, challenging the Bureau of Prisons (BOP) decision that he was ineligible to earn and apply First Step Act (FSA) time credits to his sentence.
On March 4, 2025, the Respondent (Warden of USP-Atwater) moved to dismiss the petition, arguing the issue was moot because Henry had since been deemed eligible for FSA credits.
The BOP updated Henry’s records on February 21, 2025, reflecting his eligibility for FSA time credits in response to his petition.
Henry did not oppose the motion to dismiss.
The magistrate judge reviewed the parties' filings and recommended dismissal of the case as moot because the relief requested was already granted.

Issue	Henry's Argument	Warden's Argument	Held
Mootness of Petition	BOP wrongly deemed him ineligible for FSA credits and seeks court's relief	Petitioner has received the relief sought; eligibility updated in BOP records	Petition is moot; motion to dismiss granted

Iron Arrow Honor Soc’y v. Heckler, 464 U.S. 67 (federal courts lack jurisdiction over moot cases)
Murphy v. Hunt, 455 U.S. 478 (case becomes moot when no legally cognizable interest remains)
North Carolina v. Rice, 404 U.S. 244 (courts may not decide questions that cannot affect parties’ rights)
O’Bremski v. Maass, 915 F.2d 418 (motion to dismiss may be evaluated using Rule 4 in habeas context)
White v. Lewis, 874 F.2d 599 (Rule 4 can provide procedural grounds for reviewing motion to dismiss in habeas cases)