Little v. Dallas RRM, 3:23-cv-01501-M-BT

Tammie L. Little was convicted by a jury in the Northern District of Texas of conspiracy to commit health care fraud and three counts of health care fraud.
She was sentenced to 33 months in prison, followed by two years of supervised release; the Fifth Circuit affirmed her conviction on appeal.
While incarcerated, Little filed a pro se habeas petition under 28 U.S.C. § 2241, challenging the Bureau of Prisons' (BOP) calculation of her First Step Act (FSA) credits.
Her only requested relief was to be released from BOP custody into supervised release, arguing that FSA credits had not been properly applied.
Little was released from BOP custody and began her supervised release while the petition was pending.
The magistrate judge considered whether the petition remained a live controversy after her release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of habeas petition after release	Little’s petition remained live due to alleged improper FSA credit calculation	The case is moot because Little has been released and received all relief sought	Petition dismissed as moot
Appropriateness of relief under § 2241	Little was entitled to earlier release based on proper FSA credit calculation	Credits were properly calculated; claim is unexhausted and meritless	No relief warranted; dismissed

United States Parole Comm’n v. Geraghty, 445 U.S. 388 (federal jurisdiction limited to live cases or controversies under Article III)
Powell v. McCormack, 395 U.S. 486 (case is moot when parties lack a legally cognizable interest in outcome)
Spencer v. Kemna, 523 U.S. 1 (litigants must have a continuing personal stake throughout the proceeding)
Lewis v. Cont’l Bank Corp., 494 U.S. 472 (courts must dismiss for lack of jurisdiction when a controversy becomes moot)
Ermuraki v. Renaud, 987 F.3d 384 (mootness is a threshold jurisdictional issue)