Carafas v. LaVallee, Warden

Supreme Court of United States
391 U.S. 234 (1968)

ELI5:

Rule of Law:

Federal jurisdiction over a habeas corpus petition attaches when the petition is filed while the petitioner is in custody, and that jurisdiction is not defeated by the petitioner's unconditional release from custody before the final adjudication of their claim. A case is not moot after the sentence has been served if the petitioner continues to suffer from significant collateral consequences stemming from the conviction.

Facts:

In 1960, Carafas was convicted in a New York state court of burglary and grand larceny.
He was sentenced to concurrent terms of three to five years in prison.
Carafas began serving his sentence, and while his legal challenges were ongoing, his sentence expired on March 6, 1967.
Upon expiration of his sentence, Carafas was unconditionally released from custody and parole status.
As a result of his felony conviction, Carafas was subject to several ongoing 'collateral consequences' under state and federal law.
These legal disabilities included being unable to engage in certain businesses, serve as a labor union official, vote in New York state elections, or serve as a juror.

Procedural Posture:

In 1960, Carafas was convicted of burglary and grand larceny in a New York state trial court.
On direct appeal to the Appellate Division (an intermediate state appellate court), his conviction was affirmed.
The New York Court of Appeals (the state's highest court) also affirmed the conviction.
In 1963, while in custody, Carafas filed a petition for a writ of habeas corpus in the U.S. District Court, which was ultimately dismissed on the merits.
Carafas, the petitioner, appealed to the U.S. Court of Appeals for the Second Circuit.
The Court of Appeals denied Carafas's application to proceed in forma pauperis and granted the state's motion to dismiss the appeal.
Carafas petitioned the U.S. Supreme Court for a writ of certiorari, which was granted to review the dismissal of his appeal.

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Issue:

Does the unconditional release of a habeas corpus petitioner from custody, after the petition was filed but before a final judicial decision is reached, render the case moot and terminate federal court jurisdiction?

Opinions:

Majority - Mr. Justice Fortas

No. The unconditional release of a petitioner from custody does not render their habeas corpus case moot or terminate federal jurisdiction that has already attached. The court's jurisdiction is established at the time the petition is filed, and it persists through the final disposition of the case. The case is not moot because the petitioner continues to suffer from significant 'collateral consequences' of his conviction, such as the inability to vote, serve on a jury, or engage in certain professions, which gives him a 'substantial stake in the judgment of conviction which survives the satisfaction of the sentence.' The federal habeas statute is broad, empowering courts to 'dispose of the matter as law and justice require,' not just to order a release from physical custody. Therefore, this decision overrules Parker v. Ellis, which held that release from custody mooted a habeas petition.

Concurring - Mr. Justice Harlan

The authors, who had previously joined the majority in Parker v. Ellis, stated they were now persuaded that Parker was wrongly decided. They concurred with the majority's conclusion that once a federal court's statutory power is invoked through a habeas petition filed while the petitioner is in custody, that power to adjudicate the claim does not depend upon the petitioner remaining in custody for the duration of the proceedings. They agreed with the majority that the case is not moot and that federal jurisdiction continues despite the petitioner's release.

Analysis:

This decision significantly broadened access to federal habeas corpus relief by ensuring that claims are not extinguished simply due to the slow pace of litigation. By overruling Parker v. Ellis, the Court established that jurisdiction, once attached, is not lost upon a petitioner's release. The formal recognition of 'collateral consequences' as a basis for avoiding mootness acknowledges the serious, non-custodial burdens a conviction imposes, thereby expanding the universe of cases federal courts can hear and ensuring that potentially unconstitutional convictions can be fully litigated even after a sentence is served.

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