Alaskav.Wright
Sean Wright completed his Alaska sentence for sexual-abuse convictions, moved to Tennessee, and pleaded guilty in federal court to failing to register as a sex offender. During the federal proceedings, he filed a habeas petition under Sections 2241 and 2254 challenging the Alaska conviction. The Alaska federal district court held that he was not in custody pursuant to the judgment of a State court because his state sentence had fully expired and his current custody arose from the federal conviction. The Ninth Circuit reversed, reasoning that the Alaska conviction was a necessary predicate to the federal offense. The Supreme Court held that the court of appeals had clearly erred. Under Maleng v. Cook, a completed state sentence does not continue to support Section 2254 custody merely because the conviction may enhance or serve as a predicate for a later sentence. Wright’s current judgment was entered by a federal court, so the state-custody requirement was not satisfied. The Court vacated the Ninth Circuit’s judgment and remanded for consideration of Wright’s other theories.
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