Law School Case Brief
United States Parole Comm'n v. Geraghty - 445 U.S. 388, 100 S. Ct. 1202 (1980)
U.S. Const. art. III limits federal judicial power, that is, federal-court jurisdiction, to "cases" and "controversies." This case-or-controversy limitation serves two complementary purposes. It limits the business of federal courts to questions presented in an adversary context and in a form historically viewed as capable of resolution through the judicial process, and it defines the role assigned to the judiciary in a tripartite allocation of power to assure that the federal courts will not intrude into areas committed to the other branches of government. Likewise, mootness has two aspects: when the issues presented are no longer "live" or the parties lack a legally cognizable interest in the outcome.
John M. Geraghty, after twice being denied parole from a federal prison, brought suit against petitioners in Federal District Court challenging the validity of the United States Parole Commission's Parole Release Guidelines. The District Court denied Geraghty's request for certification of the suit as a class action on behalf of a class of "all federal prisoners who are or who will become eligible for release on parole," and granted summary judgment for petitioners on the merits. Geraghty was released from prison while his appeal to the Court of Appeals was pending, but that court held that this did not render the case moot, and went on to hold, with respect to the question whether the District Court had erroneously denied class certification, that class certification would not be inappropriate, since the problems of overbroad classes and of a potential conflict of interest between respondent and other members of the putative class could be remedied by the mechanism of subclasses. Accordingly, the Court of Appeals reversed the denial of class certification and remanded the case to the District Court for an initial evaluation sua sponte of the proper subclasses.
Did the Court of Appeals err in remanding the case to the district court?
The Court held that the court of appeals properly heard Geraghty's challenge even though his personal claim had expired, limiting its holding to ruling that a case or controversy still existed, and remanded for the district court to determine whether Geraghty was the appropriate person to represent the class. The court held that the court of appeals' remand was proper, except for its direction to the district court to construct subclasses, because this was Geraghty's burden, and so the judgment was vacated and remanded as modified.
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