Stephen Edward May v. Ryan Thornell, Director, Arizona Department of Corrections, Rehabilitation and Reentry, et al.
DueProcess HabeasCorpus Jurisdiction
Whether a judgment rendered after a habeas petitioner has been unconditionally released with no collateral consequences is void for lack of subject-matter jurisdiction
Question Presented In United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (2010), which addressed the standard for vacating a judgment for lack of subject-matter jurisdiction, this Court expressly left open the question of what are the circumstances in which a jurisdictional error will render a judgment void under Fed. R. Civ. P. 60(b)(4). This case now presents this important question of federal law: Whether a judgment rendered after a habeas petitioner has been unconditionally released with no collateral consequences — and where the state does not dispute that the petitioner was no longer “in custody” pursuant to 28 U.S.C. § 2254 — is void for lack of subject-matter jurisdiction.