Moody v. Daggett

Background

A man convicted of rape in 1962 was paroled in 1966 and later convicted and jailed for two 1971 homicides. The Parole Board issued a parole violator warrant and lodged it as a detainer at the prison but did not serve it. The prisoner asked for a prompt parole-revocation hearing under earlier Supreme Court guidance, and lower courts rejected his request, leading to review by the high court.

Reasoning

The Court considered whether lodging an unexecuted warrant and detainer alone forces an immediate revocation hearing. The majority said no: the prisoner’s present loss of liberty comes from the later homicide convictions, not from the outstanding warrant. Under the prior statutes and Board practice the Board could execute the warrant, dismiss it, or defer decision until the later sentence ended. The Court relied on Morrissey to explain that the operative event triggering a full revocation hearing is execution of the warrant and custody under it, not mere issuance or filing of a detainer. The opinion also summarizes statutory changes under the Parole Commission Act, including time limits for review and added procedural steps.

Real world impact

As the Court ruled, parole authorities may postpone adversary revocation hearings while a parolee serves a separate sentence, and a full hearing is not constitutionally required until the warrant is executed. That discretion can affect whether sentences run concurrently or consecutively and may delay opportunities to preserve or present mitigating evidence.

Dissents or concurrances

Justice Stevens (joined by Justice Brennan) dissented, arguing that delay undermines fair procedure, that issuing a detainer starts the revocation process, and that prisoners have a right to a reasonably prompt hearing to avoid corrosive uncertainty.