Sanchez v. Stephens, 4:16-cv-00590

Background

Petitioner Juan Manuel Sanchez was convicted of felony DWI in Bexar County, Texas, and sentenced to three years' imprisonment; he does not challenge the conviction itself.
Sanchez filed a federal habeas petition challenging the Texas Board of Pardons and Paroles’ denial of release on mandatory supervision (early parole), asserting Ex Post Facto, Due Process, Equal Protection, and Separation of Powers claims.
The Texas Court of Criminal Appeals denied relief without a written opinion before Sanchez filed the federal petition.
While the federal habeas case was pending, Sanchez was released from custody (change of address notified to the court).
The respondent moved for summary judgment; Sanchez opposed and sought an order to show cause for immediate release.
The district court concluded Sanchez’s release rendered his sentence-administration claims moot, dismissed the petition for lack of jurisdiction, denied the pending motions as moot, and denied a certificate of appealability.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sanchez’s challenge to denial of mandatory supervision remains justiciable after his release	Sanchez contends he was wrongfully denied mandatory supervision and that constitutional violations occurred in parole eligibility decisions	Respondent contends that Sanchez’s release eliminates any live controversy and deprives the court of jurisdiction	Mootness: Court held the petition is moot because Sanchez’s release ends the concrete injury and there is no ongoing case-or-controversy
Whether habeas relief is available for sentence-administration claims after release	Sanchez argues his sentence-administration claims remain actionable despite release	Respondent argues habeas jurisdiction requires a current concrete injury traceable to detention or supervision terms	Court held that where petitioner does not attack conviction, release removes presumption of continuing collateral consequences and jurisdiction is lacking
Whether a certificate of appealability should issue	Sanchez implicitly seeks leave to appeal district court dismissal	Respondent opposed relief; court evaluated standard for COA issuance	COA denied: reasonable jurists would not debate that release rendered the petition moot
Whether pending motions should be decided on merits after release	Sanchez sought immediate relief; respondent sought summary judgment	Both parties sought relief but factual change occurred (release)	Both motions denied as moot because court lacked jurisdiction to grant substantive relief

Key Cases Cited

Spencer v. Kemna, 523 U.S. 1 (1998) (a habeas petition challenging only sentence administration becomes moot upon petitioner’s release absent continuing collateral consequences)
Lewis v. Continental Bank Corp., 494 U.S. 472 (1990) (Article III requires a continuing personal stake throughout litigation)
Lane v. Williams, 455 U.S. 624 (1982) (limitations on assuming collateral consequences for mootness analysis)
Tennard v. Dretke, 542 U.S. 274 (2004) (standard for ‘‘substantial showing of the denial of a constitutional right’’ for a certificate of appealability)
Slack v. McDaniel, 529 U.S. 473 (2000) (COA standard when denial rests on procedural grounds)
Miller-El v. Cockrell, 537 U.S. 322 (2003) (clarifies COA standards; jurists must be able to debate the district court’s resolution)
Alexander v. Johnson, 211 F.3d 895 (5th Cir. 2000) (district court may deny a COA sua sponte without further briefing)