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Oduu v. Warden — Court adopted recommendation to dismiss habeas petition as moot

Reported / Citable

Case
Ndem Oduu v. Warden, FCI Beaumont
Court
U.S. District Court for the Eastern District of Texas
Judge
Michael J. Truncale
Date Decided
September 30, 2026
Docket No.
1:25-cv-00250
Topics
Habeas Corpus, Mootness, Magistrate Judge Recommendations

Background

Ndem Oduu, a federal prisoner confined at FCI Beaumont, filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2241.

The district court referred the matter to U.S. Magistrate Judge Zack Hawthorn, who recommended on August 30, 2026, that the petition be dismissed as moot. Proper notice of the report and recommendation was given at Oduu’s last known address, and neither party filed objections.

The Court’s Holding

After reviewing the report and recommendation together with the record, pleadings, and available evidence, the district court found the magistrate judge’s factual findings and legal conclusions correct.

The court adopted the report and recommendation. The September 30 order did not itself expressly dismiss the petition; it stated that a final judgment would be entered in accordance with the magistrate judge’s recommendation.

Key Takeaways

  • The court adopted the recommendation that Oduu’s § 2241 petition be dismissed as moot.
  • No party objected after proper notice was given at Oduu’s last known address.
  • The order contemplated a separate final judgment rather than itself expressly dismissing the petition.

Why It Matters

The order illustrates the procedural distinction between adopting a magistrate judge’s recommendation and entering the final judgment that formally disposes of the case.

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