Sandra Natasha St. John was convicted in Massachusetts state court in 2010 for attacking and severely injuring two people, receiving a sentence of ten to eleven years in prison. After serving her sentence, she was released into federal immigration custody and subsequently deported to Trinidad and Tobago in January 2024. Following her release from state prison in December 2021, she sought a new trial in state court based on newly discovered evidence suggesting her original attorney was ineffective, but the motion was denied. In March 2024, while living in Trinidad and Tobago, St. John filed a federal habeas corpus petition challenging her state conviction, alleging ineffective assistance of counsel. She named the Massachusetts Attorney General as the respondent. The district court dismissed the petition for lack of jurisdiction, ruling that St. John was no longer in custody of the Commonwealth of Massachusetts when she filed, as required by the habeas statute.
The First Circuit analyzed the fundamental statutory requirement that a habeas corpus petitioner must be 'in custody' of the state authorities at the time the petition is filed. The court reiterated that custody is the 'essential statutory ingredient for initial jurisdiction' under 28 U.S.C. § 2254(a). While the court acknowledged that 'something less than physical custody' can satisfy this requirement—such as for parolees or probationers who remain under state supervision—it emphasized that the petitioner must be subject to 'restraints not shared by the public generally' and 'at the least, to some type of continuing governmental supervision.' The court found that St. John was not in the custody, physical or otherwise, of the Commonwealth of Massachusetts when she filed her petition in March 2024, as she had been released to federal authorities in 2021 and deported in 2024. The court declined to decide whether permanent exclusion from the United States could ever constitute 'constructive custody' because the petition failed on a separate, fatal ground: the requirement to name the proper custodian. The statute mandates that the writ be directed to the person who has custody of the petitioner. Since no Massachusetts officer had custody of St. John, she failed to name a proper respondent, necessitating dismissal.
The decision reinforces the strict jurisdictional bar for federal habeas petitions filed by individuals who are no longer in state custody, including those who have been deported. Petitioners must ensure they are physically or constructively in custody of the state at the time of filing to invoke federal jurisdiction. The ruling leaves open the question of whether permanent exclusion from the United States could ever satisfy the custody requirement, but confirms that a petitioner cannot name a state official as a respondent if that official has no actual or constructive control over the petitioner. The case was remanded to the district court with instructions to affirm the dismissal.
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