NEWARK, NJ – A federal judge has dismissed a habeas corpus petition filed by a former Fort Dix inmate who claimed the Bureau of Prisons wrongly denied him earned time credits under the First Step Act — because the man is no longer in custody.
Martin Reyes, who filed his petition in June seeking immediate relief over allegedly miscalculated release dates, was released from federal custody on July 29, weeks before the court could rule on the matter. On Monday, U.S. District Judge Edward S. Kiel ruled the case is now moot under Article III of the Constitution, which requires a live controversy for a federal court to retain jurisdiction.
Reyes argued that prison officials at Fort Dix improperly placed him in “refusal” status, making him ineligible for time credits that could have shortened his incarceration. He claimed that the Bureau of Prisons failed to follow provisions of the First Step Act, which allows eligible inmates to earn reductions in their sentences by participating in certain programs.
Initially, the Bureau projected Reyes’ release for December 16, 2025. But by early August, the court’s own review of the Bureau’s inmate database showed that Reyes had already been released in late July. The court then ordered the government to confirm the release and respond on the issue of mootness.
Responding last week, Warden R. Thompson confirmed that Reyes was no longer in custody, and argued that the court could not grant retroactive relief once the custodial sentence had ended.
Judge Kiel agreed, citing binding precedent that prohibits courts from crediting excess prison time toward supervised release. The judge referenced a 2000 Supreme Court decision, United States v. Johnson, which held that while an inmate can challenge improper custody while still confined, such relief becomes unavailable upon release.
Because Reyes is no longer incarcerated and no additional remedy exists under the law, his petition was dismissed.
