Ronald Northcraft v. Chadwick Dotson

Summary

The United States District Court for the Eastern District of Virginia dismissed Ronald Northcraft’s 28 U.S.C. § 2254 petition for lack of jurisdiction because he was no longer in custody under the challenged convictions when he filed it. The court granted the respondent’s motion to dismiss, denied the petitioner’s motion to transfer venue and opposition to dismissal, and denied a certificate of appealability.

Holdings

1. A petitioner must be in custody under the conviction or sentence being challenged when a § 2254 petition is filed. Because Petitioner had completed both his incarceration and post-release supervision before filing, he was not in custody and the district court lacked jurisdiction.

Questions Presented

1. Whether the district court had jurisdiction under 28 U.S.C. § 2254 when Petitioner was no longer in custody under the challenged convictions or sentences at the time he filed the petition.

Disposition

dismissed