## Facts

- Two Illinois defendants pleaded guilty to separate burglary charges in 1975 under negotiated sentences that, by law, included a mandatory three-year parole term.
- At their plea hearings, neither defendant was told that the sentence included the mandatory parole term.
- Each defendant served the negotiated prison term, was released on parole, then was reincarcerated for violating parole.
- While in custody for the parole violations, they filed federal habeas petitions alleging due process violations from the failure to advise them of the mandatory parole term before accepting their guilty pleas.
- The district court granted relief consistent with the relief requested: release through “specific performance” of the plea bargains by eliminating the parole terms rather than vacating the guilty pleas.
- After further proceedings, and after the defendants had been fully discharged from custody, the district court entered an order declaring the mandatory parole terms void.
- The Seventh Circuit affirmed.

## Issues

1. Whether the habeas petitions presented a live Article III case or controversy after the mandatory parole terms had fully expired and the petitioners were no longer in custody.
2. Whether the collateral-consequences doctrine or the “capable of repetition, yet evading review” exception prevented mootness when petitioners sought only elimination of the parole terms rather than vacatur of the convictions.

## Decision

- The Supreme Court held the cases moot.
- The Court treated the petitions as challenges only to the parole portions of the sentences because the petitioners sought “specific enforcement” eliminating parole rather than vacating the guilty pleas.
- Because the challenged parole terms had expired, petitioners were no longer subject to any direct restraint from those terms.
- The Court declined to presume collateral consequences from an expired parole term and found none identified that were traceable to the parole term (as opposed to the convictions).
- The “capable of repetition, yet evading review” exception did not apply because there was no reasonable expectation the same parties would again be subjected to the same alleged wrong under conditions preventing review.
- The Court vacated the Seventh Circuit’s judgment and remanded with directions to dismiss as moot, assuming without deciding that the pleas could have been constitutionally defective.

## Legal Principles

- A habeas case challenging only a component of a sentence becomes moot once the challenged component fully expires, absent concrete, continuing collateral consequences traceable to that component.
- Collateral consequences are generally presumed for criminal convictions, so a direct attack on a conviction is not necessarily mooted by expiration of the sentence; that presumption does not automatically extend to an expired sentencing component attacked in isolation.
- Mootness analysis in habeas focuses on the relief sought; selecting a remedy that targets only an expired sentencing term can eliminate the live controversy.
- The “capable of repetition, yet evading review” exception requires a reasonable expectation that the same complaining party will again face the same action and that the action is too short in duration to be fully litigated.

## Conclusion

Because the petitioners sought only to void mandatory parole terms that had already expired and identified no ongoing collateral consequences from those terms, the Supreme Court held there was no live controversy and ordered dismissal for mootness without reaching the due process merits of the guilty pleas.


Lane v. Williams, 455 U.S. 624 (1982)