Manzo-Hernandez v. Saucedo
21-40034
| 5th Cir. | Nov 30, 2021Background
- Five undocumented immigrants were arrested by Border Patrol and detained at La Salle County Regional Detention Center (Jan–Mar 2020) as material witnesses under 18 U.S.C. § 3144; they were never criminally charged.
- Nearly identical affidavits requested designation/detention as material witnesses and set $25,000 bond pending disposition; detainees had only a brief initial appearance and no subsequent individualized findings.
- Petitioners filed a § 2241 habeas petition seeking release, injunctive relief against the assistant warden, and declaratory relief; they also sought to represent a putative class of ~156 similarly situated individuals.
- The district court denied class certification without prejudice (reserving ruling until after motion to dismiss), then construed the Government’s motion as a 12(b)(1)/12(b)(6) dismissal and declined to exercise habeas jurisdiction, dismissing the case; petitioners did not appeal the class-certification denial.
- By the time of appeal all named petitioners had been released; the Fifth Circuit held the individual and class claims moot and dismissed the appeal for lack of Article III jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether individual habeas and injunctive claims are moot after release | Petitioners contend release does not moot injunctive/declaratory claims and they may pursue relief and class claims | Release moots individual habeas claims absent collateral consequences or showing of continuing injury | Moot: petitioners offered no collateral consequences or realistic threat of repeated injury; individual claims moot |
| Whether class claims survive when named plaintiffs’ claims are satisfied pre-certification | Petitioners invoke Sosna/Geraghty and the "inherently transitory" exception to avoid mootness | Government: class claims moot because named plaintiffs released and petitioners did not appeal denial of class certification; procedural changes irrelevant | Moot: Sosna/Geraghty inapplicable because class was not certified and denial was not appealed; inherently transitory exception not met |
| Whether district court abused discretion by dismissing habeas petition (declining to exercise § 2241 authority) | Petitioners argue district erred in refusing to exercise habeas jurisdiction | Government defends discretionary dismissal | Not reached on the merits: Fifth Circuit did not resolve the standard or abuse-of-discretion claim because case was moot |
| Whether mootness exceptions (capable of repetition yet evading review; voluntary cessation) apply | Petitioners assert exceptions apply and that they relied on district-court assurances | Government disputes applicability and cites lack of reasonable expectation of recurrence | Exceptions inapplicable: no reasonable expectation of recurrence and petitioners failed to show continuing or repeating injury |
Key Cases Cited
- Already, LLC v. Nike, Inc., 568 U.S. 85 (2013) (mootness occurs when issues are no longer live or parties lack a cognizable interest)
- Alvarez v. Smith, 558 U.S. 87 (2009) (failure to appeal denial of class certification moots the named plaintiffs’ claims)
- Sosna v. Iowa, 419 U.S. 393 (1975) (a certified class acquires independent legal status that can avoid mootness)
- United States Parole Comm’n v. Geraghty, 445 U.S. 388 (1980) (putative class may proceed where certification would have occurred but for erroneous denial that is timely appealed)
- Gerstein v. Pugh, 420 U.S. 103 (1975) (discussing pretrial-detainee class actions and inherently transitory claims)
- Spencer v. Kemna, 523 U.S. 1 (1998) (capable-of-repetition exception requires reasonable likelihood of recurrence)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (mootness is a jurisdictional requirement under Article III)
- Opulent Life Church v. City of Holly Springs, 697 F.3d 279 (5th Cir. 2012) (distinguishing damages claims from injunctive/declaratory claims for mootness)
- Murray v. Fidelity Nat’l Fin., Inc., 594 F.3d 419 (5th Cir. 2010) (purported class action becomes moot when personal claims of all named plaintiffs are satisfied)