Stephen Yagman v. Linda Thomas

Linda Thomas appeals a district court order granting Stephen Yagman’s § 2241 habeas corpus petition. The district court found that the Bureau of Prisons violated Yagman’s due process rights in a prison disciplinary hearing. Thomas argues that the case was moot when decided because the disciplinary hearing had been vacated and the record expunged before the district court entered its final order.

The case became moot when the Bureau of Prisons vacated the disciplinary proceedings, because there was no further relief that could have been given to Yag-man. Though Yagman was still on supervised release at the time the district court issued its order, the expunged discipline record could not have affected his custody, had supervised release been revoked, nor could the expunged discipline record have had other adverse consequences.

Significantly, the Bureau of Prisons vacated the disciplinary proceedings before the district court issued its order. Although the Bureau of Prisons vacated the disciplinary proceedings in response to the magistrate judge’s report and recommendation, the magistrate judge’s report and recommendation was not a final disposition on the matter. See Schur v.…