United States v. Rickey Warren

United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-3538 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Rickey L. Warren lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Arkansas - Central ____________ Submitted: May 19, 2026 Filed: May 26, 2026 [Unpublished] ____________ Before GRUENDER, KELLY, and KOBES, Circuit Judges. ____________ PER CURIAM.

Rickey Warren appeals after the district court1 quashed--in his favor--a writ of garnishment, revoked his supervised release, and sentenced him to 30 days in prison.

The Honorable D.P. Marshall, Jr., United States District Judge for the Eastern District of Arkansas.

We dismiss the appeal. Any challenge to the motion for a writ of garnishment is moot because the writ was quashed and there is no further relief this court can grant; and any challenge to the revocation is also moot, because Warren has already been released from custody and is no longer under court supervision. See Hillesheim v. Holiday Stationstores, Inc., 903 F.3d 786, 791 (8th Cir. 2018) (stating a claim is moot when changed circumstances have already provided the requested relief); United States v. Dunlap, 719 F.3d 865, 866-68 & n.4 (8th Cir. 2013) (per curiam) (dismissing appeal of revocation sentence as moot where defendant had completed prison sentence and was no longer on supervised release; exception to mootness for cases “capable of repetition yet evading review” applies where challenged action is too short in duration to be fully litigated prior to expiration, and there is a reasonable expectation that the same complaining party will be subject to the same action again); United States v. Williams, 483 F.3d 889, 889 (8th Cir. 2007) (per curiam) (concluding that appeal of defendant’s sentence was moot because she was released during pendency of appeal, and effective relief was thus impossible). To the extent Warren intended to raise any additional issues on appeal, we find no basis for reversal.

Accordingly, we grant counsel’s motion to withdraw, and dismiss this appeal as moot.2 ______________________________

We deny as moot Warren’s pro se motion to supplement the record on appeal with additional evidence.

-2-