Joel Marvin Munt v. Michelle Smith, Warden, MCF-OPH, A16-462

Joel Munt is serving life without parole for a 1st‑degree murder conviction.
While in the prison law library he was charged with violating a prison disorderly‑conduct rule after angrily confronting an education staff member.
A hearing officer found Munt guilty and he was placed in segregated confinement for 30 days; the associate warden upheld the sanction.
Munt completed his segregation and then filed a state habeas corpus petition seeking to overturn the disciplinary finding and related relief (e.g., vacatur, expungement, declaration of unconstitutionality).
The district court denied the habeas petition as moot, concluding habeas relief is limited to challenges to ongoing detention and cannot provide the relief Munt sought.
Munt appealed, arguing exceptions to mootness and invoking collateral consequences and federal precedent (Heck) to preserve his claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas corpus can be used to overturn completed disciplinary segregation	Munt: habeas can remedy unlawful punishment and collateral consequences of the disciplinary finding	State: habeas only provides relief from current restraint; Munt already served segregation so no present relief is available	Denied — habeas is unavailable because Munt is no longer restrained by the challenged punishment
Whether collateral‑consequences exception saves the claim from mootness	Munt: the disciplinary record will have future adverse administrative effects in prison	State: Munt offers only speculation and points to no rule showing concrete collateral consequences	Denied — no presumption of collateral consequences and Munt failed to show actual adverse effects
Whether the capable‑of‑repetition‑yet‑evading‑review exception applies	Munt: segregation is short and likely to recur, so the exception should apply	State: the petition was already moot when filed because Munt had been released from segregation before filing	Denied — exception cannot revive a claim that was moot at filing
Whether Heck doctrine prevents dismissal or preserves federal claims	Munt: favorable termination requirement (Heck) means disciplinary conviction affects future federal relief	State: Heck applies only to challenges that undermine the underlying criminal conviction	Denied — Heck inapplicable because Munt is not attacking his murder conviction

Beaulieu v. Minnesota Dept. of Human Servs., 798 N.W.2d 542 (Minn. App. 2011) (habeas relief available for detention exceeding jurisdiction or violating rights)
Rud v. Fabian, 743 N.W.2d 295 (Minn. App. 2007) (habeas is the avenue for immediate release and does not authorize other relief)
In re Schmidt, 443 N.W.2d 824 (Minn. 1989) (mootness doctrine and exceptions, including capable‑of‑repetition‑yet‑evading‑review)
In re McCaskill, 603 N.W.2d 326 (Minn. 1999) (collateral‑consequences rule and when presumption attaches)
Heck v. Humphrey, 512 U.S. 477 (1994) (federal favorable‑termination rule for damages that would imply conviction invalidity)
Muhammad v. Close, 540 U.S. 749 (2004) (Heck does not automatically apply to all prison‑discipline challenges)