Dongelyan v. Prairieland Detention Center

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
AKOP D., §
§
Petitioner, §
§
V. § No. 3:25-cv-2502-L-BN
§
PRAIRIELAND DETENTION CENTER, §
§
Defendant. §
FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE
UNITED STATES MAGISTRATE JUDGE
Petitioner, detained at Prairieland Detention Center in this district at the time
of filing, filed a pro se 28 U.S.C. § 2241 habeas petition challenging his detention. See
Dkt. No. 3. United States District Judge Sam A. Lindsay referred this habeas case to
the undersigned United States magistrate judge for pretrial management under 28
U.S.C. § 636(b) and a standing order of reference.
On January 30, 2026, the government filed a status update, requesting
dismissal of the action because Petitioner had been removed from the United States
on October 20, 2025. See Dkt. No. 11.
While Petitioner “satisfied the jurisdictional ‘in custody’ requirement for
purposes of pursuing relief under § 2241 at the time [he] filed [his] petition,” Herndon
v. Upton, 985 F.3d 443, 446 (5th Cir. 2021) (citing 28 U.S.C. § 2241(c)(3); Maleng v.
Cook, 490 U.S. 488, 490-91 (1989)), he “must separately satisfy the case-or-
controversy requirement of Article III, Section 2 of the Constitution,” id. (citing
Spencer v. Kemna, 523 U.S. 1, 7 (1998)), because a federal court’s jurisdiction is
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“constrained to adjudicating ‘actual, ongoing controversies between litigants,’” id.
(quoting Deakins v. Monaghan, 484 U.S. 193, 199 (1988)).
“‘In order to maintain jurisdiction, the court must have before it an actual case
or controversy at all stages of the judicial proceedings.’ ‘A case becomes moot only
when it is impossible for a court to grant any effectual relief whatever to the
prevailing party.’” Id. (citations omitted). “And ‘[i]t is well-settled, that mootness is a
threshold jurisdictional inquiry.’” Ermuraki v. Renaud, 987 F.3d 384, 386 (5th Cir.
2021) (per curiam) (quoting La. Env’t Action Network v. U.S. E.P.A., 382 F.3d 575,
580 (5th Cir. 2004)); see also Carbajal v. Holder, 43 F. Supp. 3d 1184, 1189 (D. Colo.
2014) (“An ‘actual controversy must be extant at all stages of review, not merely at
the time the complaint is filed.’ A case becomes moot if an event occurs during the
pendency of the action ‘that makes it impossible for the court to grant any effectual
relief whatever to a prevailing party.’” (citations omitted)).
Petitioner’s removal from the United States is an event that moots his
challenge to his detention. See, e.g., Morales-Morales v. Barr, 933 F.3d 456, 462 (5th
Cir. 2019) (“Because Morales-Morales is no longer detained and has already been
deported, her challenge to her detention is moot.” (citing Chay v. Holder, 470 F. App’x
406, 407 (5th Cir. 2012) (per curiam) (“Even if the district court retained subject
matter jurisdiction over Chay’s § 2241 petition to the extent that it challenged the
continued lawfulness of Chay’s post-removal-order detention, and not an order of
removal, any such challenge is now moot because Chay has been removed from the
United States.” (citations omitted)))).
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Petitioner’s removal therefore renders the Court without jurisdiction to render
a judgment on his claims and requires dismissal. Cf. Goldin v. Bartholow, 166 F.3d
710, 718 (5th Cir. 1999) (“If mootness occurred prior to the rendering of final
judgment by the district court, vacatur and dismissal is automatic. The district court
would not have had Article III jurisdiction to render the judgment, and we cannot
leave undisturbed a decision that lacked jurisdiction.” (citing Iron Arrow Honor Soc.
v. Heckler, 464 U.S. 67, 72-73 (1983))).
Recommendation
The Court should dismiss this action as moot.
A copy of these findings, conclusions, and recommendation shall be served on
all parties in the manner provided by law. And any party who objects to any part of
these findings, conclusions, and recommendation must file specific written objections
within 14 days after being served with a copy. See 28 U.S.C. § 636(b)(1); FED. R. CIV.
P. 72(b). In order to be specific, an objection must identify the specific finding or
recommendation to which objection is made, state the basis for the objection, and
specify the place in the magistrate judge’s findings, conclusions, and recommendation
where the disputed determination is found. An objection that merely incorporates by
reference or refers to the briefing before the magistrate judge is not specific. Failure
to file specific written objections will bar the aggrieved party from appealing the
factual findings and legal conclusions of the magistrate judge that are accepted or
adopted by the district court, except upon grounds of plain error. See Douglass v.
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United Servs. Auto. Ass’n, 79 F.3d 1415, 1417 (5th Cir. 1996).
DATED: February 3, 2026
_________________________________________
DAVID L. HORAN
UNITED STATES MAGISTRATE JUDGE
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