United States Parole Comm'n v. Geraghty
Annotate this Case
445 U.S. 388 (1980)
U.S. Supreme Court
United States Parole Comm'n v. Geraghty, 445 U.S. 388 (1980)
United States Parole Commission v. Geraghty
Argued October 2, 1979
Decided March 19, 1980
445 U.S. 388
Respondent, 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 respondent'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. Respondent 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.
Held: An action brought on behalf of a class does not become moot upon expiration of the named plaintiff's substantive claim, even though class certification has been denied, since the proposed representative of the class retains a "personal stake" in obtaining class certification sufficient to assure that Art. III values are not undermined. If the appeal from denial of the class certification results in reversal of the denial, and a class subsequently is properly certified, the merits of the class claim then may be adjudicated pursuant to the holding in Sosna v. Iowa, 419 U. S. 393, that mootness of the named plaintiff's individual claim after a class has been duly certified does not render the action moot. Pp. 445 U. S. 395-408.
(a) The fact that a named plaintiff's substantive claims are mooted due to an occurrence other than a judgment on the merits, cf. Gerstein v. Pugh, 420 U. S. 103; Deposit Guaranty Nat. Bank v. Roper, ante p. 445 U. S. 326, does not mean that all other issues in the case are mooted. A plaintiff who brings a class action presents two separate issues, one
being the claim on the merits and the other being the claim that he is entitled to represent a class. "The denial of class certification stands as an adjudication of one of the issues litigated," Roper, ante at 445 U. S. 336, and, in determining whether the plaintiff may continue to press the class certification claim after the claim on the merits "expires," the nature of the "personal stake" in the class certification claim must be examined. P. 445 U. S. 402.
(b) The imperatives of a dispute capable of judicial resolution -- sharply presented issues in a concrete factual setting and self-interested parties vigorously advocating opposing positions -- can exist with respect to the class certification issue notwithstanding that the named plaintiff's claim on the merits has expired. Such imperatives are present in this case, where the question whether class certification is appropriate remains as a concrete, sharply presented issue and respondent continues vigorously to advocate his right to have a class certified. Pp. 445 U. S. 403-404.
(c) Respondent was a proper representative for the purpose of appealing the ruling denying certification of the class that he initially defined, and hence it was not improper for the Court of Appeals to consider whether the District Court should have granted class certification. P. 445 U. S. 407.
(d) The Court of Appeals' remand of the case for consideration of subclasses was a proper disposition, except that the burden of constructing subclasses is not upon the District Court, but upon the respondent. Pp. 445 U. S. 407-408.
579 F.2d 238, vacated and remanded.
BLACKMUN, J., delivered the opinion of the Court, in which BRENNAN, WHITE, MARSHALL, and STEVENS, JJ., joined. POWELL, J., filed a dissenting opinion, in which BURGER, C.J., and STEWART and REHNQUIST, JJ., joined, post, p. 445 U. S. 409.