Case Name in Immigration Case - Unavailable

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
COLUMBUS DIVISION
M.L.K., 	:
:
Petitioner, 	:
:
v. 	: 	Case No. 4:25-cv-184-CDL-AGH
: 	28 U.S.C. § 2241
PAM BONDI, et al., 	:
:
Respondents. 	:
_________________________________
RECOMMENDATION OF DISMISSAL
Pending before the Court is Petitioner’s application for habeas relief (ECF
No. 1), and Respondents’ second motion to dismiss (ECF No. 13). 	On October 16,
2025, Respondents notified the Court that Petitioner had been removed from the
United States to Guinea. 	Resp’ts’ 2nd Mot. to Dismiss 1, ECF No. 13. 	In support,
Respondents submitted an I-205 Warrant of Removal/Deportation showing that
Petitioner was removed from the United States on September 10, 2025. Resp’ts’ Ex.
A, at 2, ECF No. 13-1. Due to Petitioner’s removal, Respondents move to dismiss his
petition as moot. 	Resp’ts’ 2nd Mot. to Dismiss 1-2. 	As explained below, the Court
recommends that the motion be granted.
“Article III of the Constitution limits the jurisdiction of federal courts to the
consideration of ‘Cases’ and ‘Controversies.’” 	Soliman v. United States, 296 F.3d
1237, 1242-43 (11th Cir. 2002) (citing U.S. Const. art. III, § 2, and finding appeal
moot where petitioner was removed from the United States). 	“The doctrine of
mootness derives directly from the case or controversy limitation because an action
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that is moot cannot be characterized as an active case or controversy.” 	Id. at 1242
(internal quotation marks omitted). 	“[P]ut another way, a case is moot when it no
longer presents a live controversy with respect to which the court can give meaningful
relief.” 	Id. (internal quotation marks omitted). 	“Therefore, ‘[i]f events that occur
subsequent to the filing of a lawsuit or an appeal deprive the court of the ability to
give the plaintiff or appellant meaningful relief, then the case is moot and must be
dismissed.’” Id. (quoting Al Najjar v. Ashcroft, 273 F.3d 1330, 1336 (11th Cir. 2001)).
Here, Petitioner sought an order granting him a writ of habeas corpus and
release from custody. Pet. 8, ECF No. 1. Petitioner was removed from the country to
Guinea and appears to no longer be in Respondents’ custody. 	Resp’ts’ 2d Mot. to
Dismiss 1-2; Resp’ts’ Ex. A, at 2, ECF No. 13-1. 	Petitioner did not respond to the
second motion to dismiss.1 Because Petitioner is no longer in Respondents’ custody,
the Court can no longer give Petitioner any meaningful relief, the case is moot, and
“dismissal is required because mootness is jurisdictional.” 	Al Najjar, 273 F.3d at
1336.
It is therefore RECOMMENDED that Respondents’ second motion to dismiss
(ECF No. 13) be GRANTED, Respondents’ first motion to dismiss (ECF No. 7) be
denied as moot, and Petitioner’s application for habeas corpus relief (ECF No. 1) be
DISMISSED as moot. Pursuant to 28 U.S.C. § 636(b)(1), the parties may serve and
file written objections to this Recommendation, or seek an extension of time to file
1 The Court sent notice (ECF No. 14) to Petitioner of his right to respond to Respondents’ second motion
to dismiss, but the notice was returned as undeliverable because he was no longer at the detention
facility. Mail Returned, ECF No. 16. The Court has no other address for Petitioner.
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objections, within FOURTEEN (14) DAYS after being served with a copy hereof. Any
objection should be no longer than TWENTY (20) PAGES in length. 	See M.D. Ga.
L.R. 7.4. The district judge shall make a de novo determination of those portions of
the 	Recommendation 	to 	which 	objection 	is 	made. 	All 	other 	portions 	of 	the
Recommendation may be reviewed for clear error.
The parties are hereby notified that, pursuant to Eleventh Circuit Rule 3-1,
“[a] party failing to object to a magistrate judge’s findings or recommendations
contained in a report and recommendation in accordance with the provisions of
28 U.S.C. § 636(b)(1) waives the right to challenge on appeal the district court’s order
based on unobjected-to factual and legal conclusions if the party was informed of the
time period for objecting and the consequences on appeal for failing to object. In the
absence of a proper objection, however, the court may review on appeal for plain error
if necessary in the interests of justice.”
SO RECOMMENDED, this 1st day of December, 2025.
s/ Amelia G. Helmick
UNITED STATES MAGISTRATE JUDGE
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