K.B. v. Austin Knudsen, Attorney General of the State of Montana; Unknown SVORA Administrator

Summary

The United States District Court for the District of Montana dismissed K.B.’s habeas petition challenging a purported sexual-offender registration requirement arising from a juvenile disposition. The court held that the petition was untimely, alleged at most issues of state-law interpretation, and failed to satisfy the custody requirement for federal habeas jurisdiction because the juvenile disposition had expired. The court denied a certificate of appealability.

Holdings

1. The petition appeared untimely because, even accounting for potential statutory and equitable tolling and the alternative triggering dates in 28 U.S.C. § 2244(d)(1), K.B. filed more than one year after he could have discovered the factual predicate of his claims.
2. A federal writ of habeas corpus is not available to correct alleged errors in the interpretation or application of state law absent a constitutional violation.
3. The district court lacked habeas jurisdiction because K.B. was not in custody under the juvenile disposition or purported sentencing conditions when he filed the federal petition.
4. A certificate of appealability should be denied because reasonable jurists would not find the jurisdictional dismissal debatable or conclude that the claims deserved encouragement to proceed further.

Questions Presented

1. Whether the petition was barred by AEDPA's one-year statute of limitations.
2. Whether alleged errors by Montana courts in interpreting or applying state juvenile sentencing and sexual-offender-registration law were cognizable in a federal habeas proceeding under 28 U.S.C. § 2254.
3. Whether the district court had habeas jurisdiction when K.B. was no longer in custody under the juvenile disposition or sentence he sought to challenge.
4. Whether K.B. was entitled to a certificate of appealability.

Disposition

dismissed