Carafas v. LaVallee

391 U.S. 234 (1968)

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Carafas v. LaVallee

United States Supreme Court
391 U.S. 234 (1968)

  • Written by Arlyn Katen, JD

Facts

James Carafas (defendant) was sentenced to a total of three to five years of incarceration in 1960 for burglary and larceny offenses. New York state courts affirmed Carafas’s conviction on direct appeal, and the United States Supreme Court denied certiorari. In 1963, Carafas applied for a writ of habeas corpus in federal district court while he was still in custody. Carafas was released on parole in 1964, and he completed his sentence and was discharged from parole on March 6, 1967. During that timeframe, the district court dismissed Carafas’s petition on its merits and the United States Court of Appeals for the Second Circuit affirmed the dismissal. The United States Supreme Court issued a writ of certiorari on October 16, 1967, to consider whether the Second Circuit erred by refusing to allow Carafas to appeal in forma pauperis and waive his legal fees. The state argued that the Supreme Court could not reach that issue because Carafas’s appeal became moot when Carafas was unconditionally released from custody (i.e., when his paroled ended).

Rule of Law

Issue

Holding and Reasoning (Fortas, J.)

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