Stanbridge v. Scott

Dist. Ct. did not err in dismissing plaintiff’s habeas petition challenging certain aspects of his 2005 criminal conviction for aggravated criminal sexual abuse, where plaintiff had already served his full sentence for his 2005 conviction, and where plaintiff was currently under civil confinement pursuant to Illinois Sexually Violent Persons Commitment Act. While defendant argued that Dist. Ct. had jurisdiction to consider his habeas petition because he still was “in custody” for purposes of his sexual abuse conviction because said conviction was necessary predicate for his current civil confinement, Dist. Ct. lacked jurisdiction to consider plaintiff’s habeas petition because plaintiff’s civil confinement was mere collateral consequence of his criminal conviction, and thus was insufficient to render him in custody pursuant to his 2005 conviction.