United States of America v. Rickey L. Warren

United States Court of Appeals
For the Eighth Circuit
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No. 25-3538
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Rickey L. Warren
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Eastern District of Arkansas - Central
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Submitted: May 19, 2026
Filed: May 26, 2026
[Unpublished]
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Before GRUENDER, KELLY, and KOBES, Circuit Judges.
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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.
1The Honorable D.P. Marshall, Jr., United States District Judge for the Eastern
District of Arkansas.

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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
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2We deny as moot Warren’s pro se motion to supplement the record on appeal
with additional evidence.
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