Wright v. Alaska, No. 19–35543 (9th Cir. 2020)
Nature of Case: Appellant was convicted of a sex offense and required to register. He subsequently moved across state lines and did not register and was indicted for failing to register. Appellant pled guilty and subsequently filed a habeas corpus petition challenging his conviction for the underlying sex offense. The district court denied the petition on the grounds that Appellant was not “in custody” on his prior sex offense. Appellant sought review.
Holding: The 9th Circuit Court of Appeals reversed, finding that where an individual is in custody on a failure to register offense, it is “positively and demonstrably related” to the predicate sex offense conviction and thus such individuals are in custody for habeas corpus purposes.