Supreme Court Clarifies Standing Requirements for Habeas Claim
In Alaska v. Wright, 593 U.S. ____ (2021), the U.S. Supreme Court maintained that if offenders have finished serving their nation court sentence, they also lack standing to bring a federal habeas claim.
Facts of this Case
In 2009, an Alaska jury condemned Sean Wright of 13 counts of sexual abuse of a minor. Wright finished serving his sentence from Alaska at 2016, and soon thereafter he moved to Tennessee. Once there, he failed to register as a sex offender as required by national law. Wright pleaded guilty to a count of failure to register, and finally obtained a sentence of time served along with five decades of supervised release.
During the course of those federal event, Wright filed a petition for a writ of habeas corpus from the United States District Court for the District of Alaska pursuant to 28 U.S.C. §§2241 and 2254. He contended that the Alaska Supreme Court had unreasonably applied clearly established federal law as it denied his Sixth Amendment claims and affirmed his 2009 state conviction and sentence. The District Court denied the motion in the brink ground that Wright was not”in custody pursuant to the judgment of a State court.” Noting that a proper motion under §2254(a) takes more than merely being”in custody” someplace, the court reasoned that”the proper procedure for Wright to challenge his current federal custody could be a motion filed in the Eastern District of Tennessee pursuant to 28 U.S.C. §2255.”
The Ninth Circuit Court of Appeals reversed. In its opinion, Wright’s state conviction was”a essential predicate” for his federal conviction, (quoting Zichko v. Idaho, 247 F. 3d 1015, 1019 (CA9 2001)), therefore Wright was in fact in custody pursuant to the judgment of a state court. The board failed to check the District Court’s opinion that §2255, instead of §2254, given the suitable path for Wright to challenge his existing custody. One judge agreed and claimed that §2254 was the suitable mechanics”because Wright is not attacking the constitutionality of his federal conviction for failing to register as a sexual offender at Tennessee; he is collaterally attacking the constitutionality of his predicate Alaska conviction for sexual abuse of a minor.”
Supreme Court’s Conclusion
Citing Maleng v. Cook, 490 U.S. 488 (1989) (per curiam), the Court further noted that a habeas petitioner does not stay”in custody” under a conviction”after the sentence imposed for it has fully expired, merely Due to the possibility that the prior conviction will be utilized to enhance the sentences imposed for
Any subsequent offenses of which he is convicted.” In that instance, the Court declared that it made no difference the possibility of a prior-conviction augmentation had materialized to the habeas petitioner in that case:”When the next sentence is imposed, it is pursuant to the next certainty the petitioner is incarcerated and is hence’in custody. ”’
According to its prior precedent, the Court concluded that the fact that Wright’s state certainty served as a predicate for his federal conviction failed to render him”in custody pursuant to the judgment of a State court” under §2254(a).
If Wright’s next conviction had been for a state crime, he independently could have fulfilled §2254(a)’s”in custody” requirement, though his capacity to attack the first conviction so could have been limited. Wright could not meet §2254(a) on that independent basis for the very simple reason that his next decision was entered by a national court. (internal citations omitted).
The Supreme Court voiced express no opinion on the other theories Wright advanced prior to the District Court to fulfilling the needs of §2254(a). It hastens the appeals court ruling and remanded the case back to the district court for proceedings in accordance with the opinion.
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