After Sean Wright was convicted for sexual abuse in Alaska’s state courts, he failed to register his sex offender status in Tennessee when he moved there after his Alaskan prison sentence ended, in violation of federal law. During the federal proceedings, Wright filed a petition for a writ of habeas corpus in Alaska, arguing that his Sixth Amendment rights were violated by that state’s courts. The petition was denied by the district court since he was not “in custody pursuant to the judgment of a State court” as required under 18 U.S.C. sec. 2254, since his state jail term had ended. The Ninth Circuit reversed, arguing that the state court’s conviction served as a “necessary predicate” for the federal charge, and thus he could bring his claim.

The Court, in a unanimous per curiam decision, summarily reversed, saying the Ninth Circuit “clearly erred.” Once the sentence imposed by the state court fully expired, the defendant was no longer “in custody” under that sentence for purposes of habeas corpus. When a second sentence is imposed, it is under that second sentence the defendant is “in custody” under, not the first, even if the first was a predicate to the second.

A link to the decision in Alaska v. Wright is here: https://www.supremecourt.gov/opinions/20pdf/20-940_c0ne.pdf