Alaska v. Wright
The Supreme Court unanimously reversed a Ninth Circuit ruling that had allowed a man to use federal habeas law to challenge an old Alaska conviction he had already fully served time for, ruling that once a state sentence expires it cannot anchor a new habeas petition even if it helped trigger a later federal charge.
The decision reaffirms a well-established rule about who is 'in custody' under federal habeas law and shuts down a legal theory that would have let prisoners collaterally attack long-expired state convictions through their subsequent federal cases.
How it got here: Wright filed a federal habeas petition in Alaska's federal district court; the court denied it; the Ninth Circuit reversed; Alaska petitioned the Supreme Court, which granted review and vacated the Ninth Circuit's ruling.
The Case in Depth
What happened
Sean Wright was convicted of sexual abuse of a minor by an Alaska jury in 2009 and finished serving his Alaska sentence in 2016. After moving to Tennessee, he was convicted in federal court for failing to register as a sex offender — a charge that depended on his Alaska conviction as a predicate. He then tried to challenge his original Alaska conviction in federal court, arguing Alaska's high court had wrongly denied his Sixth Amendment claims.
The question before the Court
Can a person use the federal habeas corpus law for state prisoners to challenge a fully-expired state conviction, just because that old conviction was a required building block for a later federal conviction?
The Court's answer
No — a person whose state sentence has completely run out is no longer "in custody" under that state conviction, and the federal habeas statute for state prisoners simply does not apply to him, even if that old conviction was a required element of a later federal charge.
The Court applied its 1989 ruling in Maleng v. Cook, which drew a clear line: once a state sentence expires, the person is in custody pursuant to whatever new conviction placed him back behind bars — not the old, expired one. When Wright's federal conviction was entered, it was that federal judgment, not his fully-served Alaska judgment, that put him in custody. The Ninth Circuit's "necessary predicate" theory cannot override that line.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People convicted under federal law — including federal sex-offender registration charges — cannot use this decision as a back door to relitigate fully served state convictions in federal court. Federal courts and defense lawyers need to file challenges to state convictions through the correct legal channel and within the right time window, or those challenges are foreclosed.
What changes now
The case goes back to the Ninth Circuit, which must now reckon with the District Court's reasoning that Wright cannot satisfy § 2254(a)'s custody requirement. The Court left open whether other legal theories Wright raised below might satisfy § 2254(a); those questions remain for the lower courts to address on remand. This is a final ruling on the specific "necessary predicate" theory the Ninth Circuit accepted.
What this does not decide
The Court explicitly declines to address other arguments Wright made below for satisfying § 2254(a)'s custody requirement. Whether any of those alternative theories might succeed — and whether § 2255 rather than § 2254 is the proper vehicle for Wright's challenge — remain open on remand.
How the Court got there
The legal reasoning, step by step
- The federal habeas corpus statute for state prisoners, 28 U.S.C. § 2254(a), allows a federal court to hear a challenge only from someone 'in custody pursuant to the judgment of a State court.' This 'in custody' requirement is the threshold gate: if Wright could not satisfy it, his challenge to the Alaska conviction could not proceed.
- In Maleng v. Cook (1989), the Court established that once a person has fully served a state sentence, he is no longer 'in custody' under that conviction — even if the old conviction might be used to increase the punishment for a later crime. The possibility (or even the reality) of an enhancement does not revive the expired custody.
- Under Maleng, when a second sentence is imposed, it is the second conviction — not the first, expired one — that places the person in custody. That rule applies squarely here: Wright finished his Alaska sentence in 2016, and his current confinement flows from his federal failure-to-register conviction entered by a federal court.
- The Ninth Circuit reasoned that because Wright's Alaska conviction was a 'necessary predicate' to his federal conviction, he was effectively in custody pursuant to the state judgment. The Court rejected this logic as inconsistent with Maleng: the predicate role of the old conviction does not transform expired state custody into current state custody.
- Had Wright's second conviction been a state conviction rather than a federal one, he might have satisfied § 2254(a)'s 'in custody' requirement on that independent basis — though his ability to attack the first conviction by that route would itself have been limited. But because his second conviction came from a federal court, no such independent basis exists.
Doctrinal impact
Cases affected by this decision
Reaffirms Maleng v. Cook (490 U. S. 488)
Confirms that an expired state sentence cannot satisfy the habeas 'in custody' requirement, even as a predicate for a new conviction.