Lane v. Williams

In Lane v. Williams, 455 U.S. 624 (1982), the respondents had filed habeas petitions challenging their sentences, which, they alleged, were imposed in violation of due process. While the case was pending on appeal, they completed their sentences and were released. The Supreme Court held that in this circumstance, the respondents claims were moot, stating: Since respondents elected only to attack their sentences, and since those sentences expired during the course of these proceedings, this case is moot. "Nullification of a conviction may have important benefits for a defendant ... but urging in a habeas corpus proceeding the correction of a sentence already served is another matter." Id. at 631 (quoting North Carolina v. Rice, 404 U.S. 244, 248 (1971)). Because respondents sought only to "remove the consequence that gave rise to the constitutional harm"--i.e., the sentences--and because the sentences had already expired, the Court determined it could no longer grant the respondents any effective relief. See id. at 631.