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United States Parole Commission v. Geraghty | 445 U.S. 388 (1980)
Under the Constitution, federal courts only have jurisdiction to hear genuine cases and controversies. Therefore, a plaintiff has to retain a personal stake in a lawsuit throughout its duration, or the case is moot. In United States Parole Commission versus Geraghty, the United States Supreme Court considered whether a plaintiff’s change in circumstances made a class action moot.
John Geraghty, a federal prisoner, was twice denied parole under the United States Parole Commission’s parole release guidelines. Geraghty filed a class action lawsuit against the commission, challenging the guidelines as unconstitutional. He petitioned the court to certify a class of similarly situated prisoners.
The trial court denied Geraghty’s request for class certification and granted summary judgment for the commission. Geraghty appealed to the Court of Appeals for the Third Circuit. While the appeal was pending, Geraghty was released from prison. The commission then moved to dismiss the appeal as moot. The appellate court denied that motion and reversed the trial court’s decision. While the commission’s petition for certiorari was pending, Geraghty filed a motion to substitute five then-incarcerated prisoners as respondents. The United States Supreme Court granted cert.
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