United States Court of Appeals

For the Eighth Circuit 

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No. 20-1509

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United States of America

 Plaintiff - Appellee

v.

James B. Mitchell

 Defendant - Appellant

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No. 20-1510

___________________________ 

United States of America

 Plaintiff - Appellee

v.

James B. Mitchell

 Defendant - Appellant

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Appeal from United States District Court 

for the Western District of Arkansas - Fayetteville

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Submitted: December 14, 2020

 Filed: January 4, 2021 

[Unpublished] 

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Before GRUENDER, ERICKSON, and KOBES, Circuit Judges. 

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PER CURIAM. 

In two separate criminal proceedings, James B. Mitchell pleaded guilty to

several federal crimes. In the first case, the district court1 sentenced Mitchell to 126 

months’ imprisonment and three years’ supervised release. In the second, the court 

sentenced Mitchell to twelve months’ imprisonment (to run consecutively with the 

priorsentence) and three years’ supervised release (to run concurrently with the prior

supervised-release term). 

Mitchell moved to reduce both sentences pursuant to 18 U.S.C. § 3582(c)(1) 

and asked for immediate release from prison. The district court denied Mitchell’s 

motion. Mitchell appeals the district court’s denial and, for the first time, also argues 

that his continued imprisonment during the COVID-19 pandemic violates the Eighth 

Amendment.

Before considering the merits, we must first determine whether we have 

subject-matter jurisdiction over Mitchell’s appeal. See, e.g., Sianis v. Jensen, 294 

F.3d 994, 997 (8th Cir. 2002) (“Subject matter jurisdiction is a threshold matter that 

we are obligated to address at the outset.”). “Under Article III of the Constitution, 

[we] may adjudicate only actual, ongoing cases or controversies.” McCarthy v. 

Ozark Sch. Dist., 359 F.3d 1029, 1035 (8th Cir. 2004) (internal quotation marks 

omitted); see also United States v. Sanders, 276 F. App’x 532, 533 (8th Cir. 2008) 

(per curiam) (same). “Thus, we will dismiss as moot a case in which changed 

1

The Honorable Timothy L. Brooks, United States District Judge for the 

Western District of Arkansas.
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circumstances have already provided the requested relief and eliminated the need for 

court action.” Teague v. Cooper, 720 F.3d 973, 976 (8th Cir. 2013) (internal 

quotation marks and brackets omitted); Sanders, 276 F. App’x at 533 (same). 

 

Here, the relief Mitchell sought from the district court was to be released from 

prison. While this appeal was pending, he was released from prison. Thus, Mitchell 

has already obtained his requested relief, and his appeal is moot. See, e.g., Tillisy v. 

Lappin, 324 F. App’x 543, 543 (8th Cir. 2009) (per curiam) (holding that a prisoner’s 

challenge of an early-release denial was moot when he had been released pending 

his appeal). 

Although Mitchell acknowledges his request for early release is now moot, he 

insists his appeal is not because we could still order the district court to reduce his 

term of supervised release. But, as Mitchell candidly concedes, he did not ask the 

district court to reduce his supervised-release term. Accordingly, Mitchell has 

already obtained what he sought from the district court. For example, in Owen v. 

United States, we dismissed a challenge to an already-completed prison term as 

moot. 930 F.3d 989, 991 (8th Cir. 2019). We rejected the argument that “there 

[was] still a live case or controversy arising from [a] continued term of supervised 

release” because the appellant had not challenged his term of supervised release

before the district court. Id. at 990. So too here, “[t]he mere fact that [Mitchell] is 

serving an unexpired, unchallenged term of supervised release does not sustain an 

actual controversy.” See id. 

For the foregoing reasons, we dismiss Mitchell’s appeal as moot.

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