Pearson v. Vogt, 6:16-cv-01978

In June–July 2016 Pearson faced criminal charges in Lane County, Oregon; a July 16, 2016 state-court fitness hearing found him "unfit to proceed," resulting in civil commitment to Oregon State Hospital (OSH) and suspension of the criminal trial.
Pearson filed a federal habeas petition under 28 U.S.C. § 2241 on October 12, 2016, seeking release from OSH and an order allowing him to resume plea negotiations to obtain probation.
On October 21, 2016 the state circuit court again addressed fitness, ordered Pearson discharged from OSH, and he subsequently completed plea bargaining and received a two‑year probation sentence.
Pearson did not pursue any further state-court review of his commitment or other state remedies, nor did he notify the federal court of an updated mailing address.
The respondent moved to dismiss; the magistrate judge recommended denial of the habeas petition and dismissal on grounds of mootness, Younger abstention/comity, and failure to exhaust state remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness	Pearson sought release from OSH and permission to resume plea bargaining; federal relief needed to obtain that result.	The state court already discharged Pearson and he entered plea/probation, so there is no live relief federal court can grant.	Case is moot because Pearson received the relief sought and no collateral consequences appear; no justiciable case or controversy exists.
"Capable of repetition yet evading review" exception	Implicitly that involuntary commitments can recur and may evade review.	The record does not show a reasonable expectation of repetition or that the process would evade review here.	Exception does not apply.
Abstention / Exhaustion (Younger/Braden principles)	Sought federal intervention into ongoing state fitness/commitment and criminal proceedings.	Federal courts should abstain; federal habeas requires exhaustion and only extraordinary circumstances justify intervention.	Abstention appropriate; Pearson failed to exhaust state remedies and did not allege extraordinary circumstances.

Murphy v. Hunt, 455 U.S. 478 (Sup. Ct. 1982) (mootness requires a live controversy to remain justiciable)
Foster v. Carson, 347 F.3d 742 (9th Cir. 2003) (explaining the "capable of repetition yet evading review" exception)
Tyars v. Finner, 709 F.2d 1274 (9th Cir. 1983) (discharge can moot habeas claims when relief sought has been granted)
Spencer v. Kemna, 523 U.S. 1 (Sup. Ct. 1998) (expired custody does not justify relief absent continuing collateral consequences)
Braden v. 30th Judicial Circuit Court of Ky., 410 U.S. 484 (Sup. Ct. 1973) (federal habeas generally requires exhaustion of state remedies before intervening in state proceedings)
Brown v. Ahern, 676 F.3d 899 (9th Cir. 2012) (extraordinary circumstances that justify federal intervention are limited to harassment or bad‑faith prosecution)
Carden v. Montana, 626 F.2d 82 (9th Cir.) (federal habeas review requires exhaustion of state remedies)