North Carolina v. Rice
404 U.S. 244 (1971)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A federal court lacks jurisdiction to hear a case challenging a sentence that has already been fully served unless the petitioner can show that specific, continuing collateral legal consequences, apart from those of the underlying conviction, would be remedied by a favorable decision.
Facts:
- On July 2, 1968, respondent Rice was arrested for driving while intoxicated on a North Carolina state highway.
- Following a trial in a county court, Rice was convicted and received a nine-month suspended sentence.
- Rice exercised his right to appeal, which under North Carolina law entitled him to a completely new trial (a trial de novo) in the Superior Court.
- After the trial de novo, Rice was again found guilty of the same offense.
- The Superior Court judge sentenced Rice to two years' imprisonment, a more severe sentence than he originally received.
- Rice fully served the two-year sentence and was officially discharged by North Carolina on January 24, 1970.
Procedural Posture:
- Rice was convicted in the General County Court of Buncombe County, North Carolina (a court of first instance).
- Rice appealed to the Superior Court for a trial de novo, where he was convicted again and received a harsher sentence.
- After exhausting state post-conviction remedies, Rice filed a petition for a writ of habeas corpus in federal district court, which was denied.
- Rice (appellant) appealed the denial to the U.S. Court of Appeals for the Fourth Circuit.
- The Court of Appeals reversed the district court's judgment, finding a due process violation and ordering Rice's conviction to be expunged.
- The State of North Carolina (petitioner) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal court have jurisdiction to hear a habeas corpus petition challenging the length of a sentence that has already been completely served, where the petitioner does not challenge the validity of the underlying conviction?
Opinions:
Majority - Per Curiam
No, a federal court does not have jurisdiction unless the petitioner can demonstrate ongoing collateral legal consequences stemming from the sentence itself. A case is moot if a court's decision cannot affect the rights of the litigants. The Court of Appeals erred by assuming the remedy for an unconstitutionally harsh sentence under North Carolina v. Pearce is the expungement of the conviction; the correct remedy is merely resentencing. Since Rice has already served his sentence and only challenges its length, not the conviction, his case is moot unless he can show that he suffers from adverse collateral consequences that flow specifically from the sentence served, rather than from the conviction. Because the record is silent on whether such consequences exist under North Carolina law, the case must be remanded for the Court of Appeals to determine if a live controversy still exists.
Dissenting - Douglas
Yes. Justice Douglas would have affirmed the judgment of the Court of Appeals, thereby implying he believed the case was not moot and that the relief granted (expungement of the conviction) was appropriate.
Analysis:
This case clarifies the application of the mootness doctrine in the context of habeas corpus petitions challenging sentences that have already been served. It establishes a critical distinction between the collateral consequences of a conviction and those of a sentence. By vacating and remanding, the Court reinforced the jurisdictional limits of Article III, requiring petitioners to demonstrate a tangible, ongoing harm to maintain a live case or controversy. The decision places the burden on the petitioner to prove that a favorable ruling on a served sentence would provide actual relief, preventing federal courts from issuing advisory opinions on sentencing.
Unlock the full brief for North Carolina v. Rice