Alaska v. Wright

Background

Sean Wright was convicted in Alaska in 2009 of sexual abuse of a minor. After finishing that sentence, he moved to Tennessee and failed to register as a sex offender, pleaded guilty in federal court to that failure, and received time served plus supervised release. While in federal proceedings, Wright asked a federal court in Alaska to review his old Alaska conviction under federal law, arguing his Sixth Amendment rights were violated.

Reasoning

The narrow question was whether Wright could bring a federal challenge aimed at his expired Alaska judgment while he was serving a federal sentence. The District Court said no, because Wright was not “in custody pursuant to the judgment of a State court.” The Ninth Circuit reversed, but the Supreme Court concluded the Ninth Circuit erred. Relying on prior rulings, the Court explained that once a state sentence has fully expired, a later federal sentence does not make the person “in custody” for the old state judgment, even if the old conviction served as a predicate for the federal charge.

Real world impact

The decision means people serving federal sentences generally cannot use the route that applies to being held under a state judgment to attack an expired state conviction. Challenges to current federal custody must be brought through the proper federal post-conviction process in the federal court that entered the later judgment. The Supreme Court vacated the Ninth Circuit’s judgment and sent the case back for further proceedings. The Court did not decide other legal ways Wright might try to meet the state-custody requirement.

Dissents or concurrances

A Ninth Circuit judge had concurred, arguing Wright was properly using the state-judgment route to attack the predicate Alaska conviction; the Supreme Court rejected that view.