Opinions and documents
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
WILLIAM F. SEVERINO,
Case No. 25–cv–17063–ESK
Petitioner,
v.
OPINION
MARK CRANSTON, et al.,
Respondents.
KIEL, U.S.D.J.
THIS MATTER is before the Court on petitioner William F. Severino’s
petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241 (Petition). (ECF
No. 1). For the following reasons, I will dismiss the Petition as moot.
I. FACTS AND PROCEDURAL HISTORY
Petitioner was a pretrial detainee in the Middlesex County Jail (Jail) when
he filed the Petition. (Id. p.1.) He challenges the New Jersey Superior
Court’s decision to deny him bail as well as the judge’s behavior during the
hearing. (Id. pp. 6, 7, 8.) On May 7, 2026, petitioner pleaded guilty to
Indictment 25–04–481–I in Middlesex County. State v. Severino, No. MID–
25–000636 (N.J. Super. Ct.).1
II. LEGAL STANDARD
Title 28, Section 2243 of the United States Code provides in relevant part:
A court, justice or judge entertaining an application for a
writ of habeas corpus shall forthwith award the writ or
issue an order directing the respondent to show cause why
the writ should not be granted, unless it appears from the
1 I take “judicial notice of the state court proceedings, which are a matter of
public record.” McDonald v. Jones, 427 F. App’x 84, 85 n. 1 (3d Cir. 2011).
application that the applicant or person detained is not
entitled thereto.
A habeas corpus petition is the proper mechanism for a federal prisoner to
challenge the “fact or duration” of his confinement. Preiser v. Rodriguez, 411
U.S. 475, 498–99 (1973); see also Muhammad v. Close, 540 U.S. 749 (2004).
A pro se pleading is held to less stringent standards than more formal
pleadings drafted by lawyers. Estelle v. Gamble, 429 U.S. 97, 106 (1976);
Haines v. Kerner, 404 U.S. 519, 520 (1972). A pro se habeas petition must be
construed liberally. See Hunterson v. DiSabato, 308 F.3d 236, 243 (3d Cir.
2002). Nevertheless, a federal district court must dismiss a habeas corpus
petition if it appears from the face of the petition that petitioner is not entitled
to relief. 28 U.S.C. § 2254 Rule 4 (made applicable through Rule 1(b)); see also
McFarland v. Scott, 512 U.S. 849, 856 (1994); Siers v. Ryan, 773 F.2d 37, 45 (3d
Cir. 1985), cert. denied, 490 U.S. 1025 (1989).
III. DISCUSSION
District courts have jurisdiction under 28 U.S.C. § 2241 to issue a writ of
habeas corpus before a criminal judgment is entered against an individual in
state court, see Moore v. De Young, 515 F.2d 437, 441–42 (3d Cir. 1975), but
“that jurisdiction must be exercised sparingly in order to prevent in the
ordinary circumstance ‘pre-trial habeas interference by federal courts in the
normal functioning of state criminal processes.’” Duran v. Thomas, 393 F.
App’x 3, 4 (3d Cir. 2010) (quoting Moore, 515 F.3d at 445–46). “The district
court should exercise its ‘pre-trial’ habeas jurisdiction only if petitioner makes
a special showing of the need for such adjudication and has exhausted state
remedies.” Moore, 515 F.2d at 443.
However, petitioner has pleaded guilty since filing the Petition. “That
guilty plea moots his § 2241 habeas petition challenging pretrial detention.”
Williams v. New Jersey, No. 18–cv–14964, 2020 WL 3259223, at *2 (D.N.J. June
16, 2020) (citing Quarles v. Pennsylvania, No. 13–cv–01994, 2014 WL 99448, *3
(E.D. Pa. Jan. 10, 2014); Padilla v. Brewington-Carr, No. 98–cv–00661, 2002
WL 100572, at *2 (D. Del. Jan. 22, 2002).) Under Article III of the
Constitution, federal courts will only have jurisdiction over a matter where
there is a live case or controversy to be resolved. See, e.g., Spencer v. Kemna,
523 U.S. 1, 7 (1998). “This case-or-controversy requirement subsists through
all stages of federal judicial proceedings [and for jurisdiction to exist the] parties
must continue to have a ‘personal stake in the outcome of the lawsuit.’” Id.
(quoting Lewis v. Continental Bank Corp., 494 U.S. 472, 477–78 (1990)).
I cannot grant petitioner any further relief pursuant to § 2241, so the
Petition is moot and must be dismissed. To the extent a certificate of
appealability is required, I decline to issue one because reasonable jurists would
agree that the Petition is moot after petitioner’s guilty plea. 28 U.S.C. § 2253;
Slack v. McDaniel, 529 U.S. 473, 484 (2000).
IV. CONCLUSION
For the reasons stated above, I will dismiss the Petition as moot. No
certificate of appealability shall issue. An appropriate Order accompanies this
Opinion.
/s/ Edward S. Kiel
EDWARD S. KIEL
UNITED STATES DISTRICT JUDGE
Dated: July 1, 2026
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