Court, Explained
U.S. District Court · District of Minnesota
←Back to docket
Substantive rulingFiled Dec. 10, 2025

MacDermott v. Rardin

Judge
John Tunheim
Docket
0:25-cv-00005
Court
U.S. District Court · District of Minnesota
Pages
9
HabeasCivil ProcedurePro SeCriminal
In one sentence

In MacDermott v. Rardin, Judge Tunheim dismissed without prejudice Troy Nicholas MacDermott's petition challenging a prison disciplinary proceeding that cost him 27 days of good-time credit, because MacDermott was released from custody on October 1, 2025, making the case moot.

Who this affects

Federal prisoners who lose good-time credit through BOP disciplinary proceedings and are subsequently released from custody before their habeas petition challenging that proceeding is resolved. This ruling illustrates that release from prison will typically render such a petition moot, ending the court case without a decision on the merits.

What happened

In MacDermott v. Rardin (Civil No. 25-05), Troy Nicholas MacDermott filed a petition asking a federal court to restore 27 days of good-time credit that the Bureau of Prisons (BOP) revoked after a disciplinary proceeding at the Federal Medical Center in Rochester, Minnesota. MacDermott argued the disciplinary process was unlawful in ten different ways and sought early release by having those days restored. A Magistrate Judge had recommended denying the petition outright, and MacDermott then filed additional motions challenging that recommendation.

While the court was reviewing those filings, MacDermott was released from federal custody on October 1, 2025 — the very date the BOP had originally projected as his release date even after the good-time credit was taken away. The government confirmed his release in a status report filed November 14, 2025. Federal courts are only permitted to decide live disputes, so once MacDermott was no longer in custody and the court could no longer order him released sooner, there was no meaningful relief the court could provide. The court examined four recognized exceptions that can keep such a case alive even after release, but found none of them applied: there were no lasting legal harms from the disciplinary record, the situation was unlikely to repeat, the government did not simply stop the challenged conduct on its own, and the case was not a class action.

Judge Tunheim denied MacDermott's petition as moot, denied his motions to amend the judgment and for extra time to file those motions, rejected the Magistrate Judge's earlier recommendation as moot, and dismissed the entire action without prejudice — meaning MacDermott could potentially bring a new lawsuit if circumstances change. The court also noted briefly that even if the case were not moot, MacDermott's specific legal arguments (including claims under the Administrative Procedure Act and reliance on an out-of-district court case) would not have succeeded on the merits.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Troy Nicholas MacDermott v. Jared Rardin, Warden, Civil No. 25-05 (JRT/DLM)
Court
United States District Court, District of Minnesota
Judge
John R. Tunheim, United States District Judge
Date
December 10, 2025

Background

Troy Nicholas MacDermott, appearing without a lawyer (pro se), filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241 — a federal statute allowing prisoners to challenge the legality of their confinement. He was serving an 86-month prison sentence followed by 40 years of supervised release. While housed at the Federal Medical Center in Rochester, Minnesota, MacDermott was involved in an incident with another inmate that led the Bureau of Prisons (BOP) to revoke 27 days of his earned good-time credit. His projected release date with the good-time credit intact had been October 1, 2025; the revocation would have pushed that date back by 27 days.

MacDermott's petition raised ten grounds challenging the disciplinary proceeding and one ground based on the timeliness of the court's ruling. He sought restoration of the 27 days so he could be released sooner, and also sought expungement of his disciplinary record.

Procedural History

- January 2, 2025: MacDermott filed his habeas petition (Docket No. 1). - January 21, 2025: The government filed a declaration (Docket No. 12) from Anna Fitcher regarding MacDermott's sentence and release date. - May 8, 2025: Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) (Docket No. 21) recommending that the petition be denied and dismissed with prejudice. - May 14, 2025: The court adopted a separate January 7 R&R and denied MacDermott's request for preliminary injunctive relief (Docket No. 22). - July 30, 2025: MacDermott filed a Motion to Alter or Amend the Judgment under Federal Rule of Civil Procedure 59(e) (Docket No. 24) and a Request for Equitable Tolling of the Rule 59(e) deadline (Docket No. 25). - October 1, 2025: MacDermott was released from BOP custody. - October 29, 2025: The court issued an Order to Show Cause directing the government to confirm MacDermott's release (Docket No. 27). - November 14, 2025: The government filed a status report confirming MacDermott's release (Docket No. 28). - December 10, 2025: Judge Tunheim issued the present Memorandum Opinion and Order.

Legal Framework — Mootness

Under Article III of the U.S. Constitution, federal courts may only hear actual 'Cases' and 'Controversies.' A live dispute must exist throughout the entire proceeding. If a court can no longer provide meaningful relief, the action is moot and must be dismissed. Brazil v. Ark. Dep't of Hum. Servs., 892 F.3d 957, 959 (8th Cir. 2018). The court also considered four recognized exceptions that can prevent dismissal even when the petitioner is released from custody: (1) collateral consequences that survive release; (2) issues capable of repetition yet evading review; (3) voluntary cessation of unlawful conduct; and (4) properly certified class actions. Ahmed v. Sessions, No. 16-2124, 2017 WL 3267738 (D. Minn. July 11, 2017).

Mootness Analysis

The court found MacDermott's release on October 1, 2025 rendered his petition moot because the court could no longer grant effective relief — he was already out of BOP custody. Ali v. Cangemi, 419 F.3d 722, 723 (8th Cir. 2005).

The court rejected all four exceptions:

  1. Collateral consequences: No evidence in the record that MacDermott suffered or would suffer cognizable collateral consequences. The court noted, relying on 28 C.F.R. § 2.35(b) and James v. Outlaw, 142 F. App'x 274 (8th Cir. 2005), that restoring the good-time credit would have no effect on his term of supervised release. The request to expunge the disciplinary record was also found moot because the record's relevance to his sentence ended upon release.
  2. Capable of repetition yet evading review: No indication MacDermott will again be held in BOP custody or subject to the same disciplinary situation.
  3. Voluntary cessation: MacDermott has been released. Any future BOP custody would present different facts, making it impossible to repeat the identical conduct challenged here. Kargbo v. Brott, No. 15-2713, 2016 WL 3676162 (D. Minn. July 6, 2016).
  4. Class action: MacDermott filed individually, not on behalf of a class.

Merits Discussion (Alternative Holding)

Although the case was dismissed as moot, Judge Tunheim noted that even if it were not moot, MacDermott's objections would fail: - Administrative Procedure Act (APA) argument: MacDermott argued the disciplinary hearings violated the APA. The court rejected this because 18 U.S.C. § 3625 expressly precludes APA review of BOP disciplinary determinations involving good-time credit. - Reliance on Lao v. Schult, No. 9:09-00653, 2010 WL 743757 (N.D.N.Y. Feb. 25, 2010): The court was not bound by another district court's decision. Moreover, Lao relied on a 'good cause' provision in 28 C.F.R. § 541.15 that no longer exists in the current regulation (28 C.F.R. § 541.5). - 'Some evidence' standard: The court agreed with the Magistrate Judge that the disciplinary determination was supported by 'some evidence in the record,' satisfying the constitutional due process standard established in Superintendent, Mass. Corr. Inst., Walpole v. Hill, 472 U.S. 445, 454 (1985).

Disposition:

  1. Petition for Writ of Habeas Corpus (Docket No. 1): DENIED as moot.
  2. Motion to Alter or Amend the Judgment (Docket No. 24): DENIED as moot.
  3. Request for Equitable Tolling of Rule 59(e) Deadline (Docket No. 25): DENIED as moot.
  4. Report and Recommendation (Docket No. 21): REJECTED as moot.
  5. Action: DISMISSED without prejudice (meaning MacDermott is not barred from bringing a new lawsuit if circumstances warrant).

Judgment was ordered to be entered accordingly.

Reviewer note from the AI+
The opinion references an 'Order Accepting R&R' from May 14, 2025 regarding a 'January 7th R&R' related to preliminary injunctive relief (Docket No. 22), but the background describes a May 8, 2025 R&R on the merits. These appear to be two separate R&Rs. The opinion is slightly unclear about the January 7 R&R's content; the summary reflects only what the opinion itself states. Judge's name read from the signature as 'JOHN R. TUNHEIM' — clearly legible. Confidence is high.
The authoritative version

Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
Summary written with AI assistance. See how summaries are made. Spot something wrong? Tell us.