WILLIAMS v. ALLEN
1:24-cv-01734
S.D. Ind.May 30, 2025Background
- George Williams, a prisoner, filed a habeas corpus petition under 28 U.S.C. § 2254 challenging a prison disciplinary conviction for trafficking, which resulted in a demotion in his good-time credit-earning class.
- The court ordered the respondent (Trent Allen, representing the Indiana Dept. of Corrections) to either hold an evidentiary hearing or vacate the disciplinary sanctions and recalculate Williams’s sentence.
- The respondent chose to vacate the original sanctions and recalculate good-time credits and sentence, rather than proceed to a hearing.
- Williams opposed the respondent’s subsequent motion to dismiss, arguing that while vacatur was proper, the respondent should not be allowed to schedule a rehearing on the same disciplinary charge.
- The disciplinary action and its sanctions have been vacated, and the underlying issues that would affect custody (and thus form a viable habeas claim) are no longer present.
- The case comes before the court on respondent’s motion to dismiss the petition as moot.
Issues
| Issue | Williams's Argument | Allen's Argument | Held |
|---|---|---|---|
| Mootness of Habeas Action | Only vacatur is proper; rehearing should not proceed | Petition is moot after vacatur | Case is moot and dismissed |
| Effect of Vacatur and Recalculation | Vacatur not sufficient if rehearing is allowed | Recalculation resolves custody | Respondent complied with order |
| Jurisdiction after Sanctions Vacated | Sanctions not fully resolved if rehearing scheduled | No live controversy remains | Court lacks jurisdiction |
| Legality of Scheduling Rehearing | Rehearing not permissible post-vacatur | Rehearing allowed by precedent | Rehearing not barred by law |
Key Cases Cited
- Brown v. Watters, 599 F.3d 602 (7th Cir. 2010) (Habeas corpus requires petitioner to be in custody in violation of federal law.)
- Cochran v. Buss, 381 F.3d 637 (7th Cir. 2004) (Habeas for prison disciplinaries requires deprivation of good-time credits.)
- Montgomery v. Anderson, 262 F.3d 641 (7th Cir. 2001) (Petitioner must show loss of credit-earning class for habeas jurisdiction.)
- Church of Scientology of Cal. v. United States, 506 U.S. 9 (1992) (Case is moot if court cannot grant effectual relief.)
- Erie v. Pap's A.M., 529 U.S. 277 (2000) (A case is moot when parties lack a legally cognizable interest.)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (Court must dismiss for lack of subject matter jurisdiction if moot.)