Wells v. King

Background Carl D. Wells, who was incarcerated at Clinton Correctional Facility, filed a petition under Section 2254, the federal law that allows a person in state custody to challenge a conviction on constitutional or federal-law grounds. He challenged a June 11, 2008 conviction in New York Supreme Court, Bronx County. He had pleaded guilty to operating a motor vehicle while impaired by drugs and to driving while impaired by the combined influence of drugs or alcohol and drugs. The state court imposed a six-month incarceration sentence.

The New York Appellate Division affirmed the conviction in 2012. The New York Court of Appeals granted leave to appeal and later vacated the judgment of conviction on November 14, 2013. The opinion states that Wells had not been in custody under that Bronx County conviction for more than 15 years when he filed the present petition.

Earlier Petition Wells had previously filed a federal petition challenging the same conviction. In that earlier round of the case, the court denied the petition for lack of jurisdiction. The court determined that Wells’s six-month sentence had expired, at the latest, on December 11, 2008, and that Wells was not in custody under the Bronx County conviction when he filed that petition. The Second Circuit later dismissed his appeal.

Present Petition Wells signed and apparently placed the present petition in his prison’s mail system on August 30, 2024; the court received it on September 10, 2024. The court held that it lacked jurisdiction because Wells was not in custody under the conviction he was challenging when he filed the petition. Section 2254 requires the petitioner to be in custody under the state-court judgment being challenged.

The court also held that the petition was moot. A matter is moot when the court can no longer provide effective relief. Here, the challenged conviction had already been vacated by the New York Court of Appeals more than a decade before Wells filed the present petition.

Disposition The court denied the present Section 2254 petition for lack of habeas corpus jurisdiction and as moot. It directed the Clerk of Court to enter a judgment dismissing the action. A footnote states that the denial was without prejudice to Wells filing a separate civil action raising claims about his conditions of confinement.

The court also warned Wells that, if he filed another petition in that court challenging the same conviction or sentence, the court might require him to explain why it should not bar him from filing future petitions about that conviction or sentence without the court’s permission.