Stephen Edward May v. Ryan Thornell, Director, Arizona Department of Corrections, Rehabilitation and Reentry, et al.

In United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (2010), which addressed the standard for vacating a judgment for lack of subject-matter jurisdiction, this Court expressly left open the question of what are the circumstances in which a jurisdictional error will render a judgment void under Fed. R. Civ. P. 60(b)(4). This case now presents this important question of federal law: Whether a judgment rendered after a habeas petitioner has been unconditionally released with no collateral consequences – and where the state does not dispute that the petitioner was no longer “in custody” pursuant to 28 U.S.C. § 2254 – is void for lack of subject-matter jurisdiction.