Supreme Court Rules Favorably in Alaska V. Wright
April 27, 2021
(Anchorage, AK) - In Alaska v. Wright, the United States Supreme Court summarily reversed a Ninth Circuit ruling which allowed Wright to challenge his underlying state conviction through a federal habeas claim, even though he had fully served his state sentence. An individual can petition a court for a release from custody by filing a habeas claim. In this case, however, Wright was not in the custody or the supervision of the State of Alaska at the time he filed his habeas claim against the State.
This decision brings finality to state court judgments. The Supreme Court here emphasized its “enduring respect for ‘the State’s interest in the finality of convictions that have survived direct review within the state court system’ . . . [t]o unsettle [finality] expectations is to inflict a profound injury” on the States and the victims of crime. And that is precisely the harm that today’s decision has undone and made right.
Wright was convicted in 2009 in Alaska state court for multiple counts of sexual abuse of a minor. For these convictions Wright was sentenced to 14 years’ imprisonment with 2 years suspended. He finished serving this sentence in 2016, including all probation and parole supervision; at that point his only remaining obligation under Alaska law was to register as a sex offender if he remained in the State. He chose not to do so and moved to Tennessee. In Tennessee, Wright failed to register as a sex offender as required by federal law. As a result, he was incarcerated in Tennessee in 2017, released following a guilty plea in February 2018, and ultimately sentenced to time served and five years’ supervised release in March 2019.
In February 2018, two years after he fully completed his sentence for his Alaska crimes, Wright filed a petition for federal habeas relief in Alaska, challenging his Alaska state-court convictions. The district court dismissed for lack of jurisdiction, concluding that Wright was not in custody pursuant to his Alaska convictions because he had already fully served his sentence. The Ninth Circuit reversed, holding that the supervised release Wright was serving pursuant to his federal failure-to-register conviction rendered him in custody pursuant to his Alaska sex-offense convictions. The consequence of the Ninth Circuit’s decision would have been to allow offenders to challenge under 28 U.S. Code § 2254(a) fully-served state convictions simply because those convictions served as predicates for subsequent federal status offenses—such as felon in possession of a firearm or failure to register as a sex offender. This result directly contradicts the plain text of Section 2254(a) as well as previous Supreme Court decisions and it threatened to confuse habeas practice nationwide.
The Supreme Court reversed the Ninth Circuit decision and reiterated that a federal court lacks subject-matter jurisdiction under Section 2254(a) to entertain a habeas petition by a person who is no longer “in custody pursuant to the judgment of a State court.” In other words, if the offender has finished serving their state court sentence, they lack standing to bring a federal habeas claim regardless of any collateral consequences of the conviction, such as sex offender registry requirements. Although Wright’s state conviction served as a predicate for his federal conviction it did not render him ‘in custody pursuant to the judgment of a State court under Section 2254(a) and allow for additional attacks on his state court conviction.
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Department Media Contact: Assistant Attorney General Charlotte Rand.