St. Pierre v. United States

Supreme Court of the United States · 1943 · Federal Courts

Federal CourtsMootnessCase or Controversymootnesscase or controversycontemptcompleted sentenceadvisory opinions

Facts

Petitioner allegedly testified before a federal grand jury that he had committed embezzlement, but he refused to identify the person whose money he had embezzled. For that refusal, the district court sentenced him to five months' imprisonment for contempt, and the court of appeals affirmed. By the time the Supreme Court considered the case, it was conceded that petitioner had fully served his sentence before certiorari was granted. The government also admitted that petitioner would be required to testify again before the grand jury and that if he again refused, it would seek to have him committed until he answered.

Issue

Whether petitioner's challenge to his contempt conviction was moot after he had fully served and completed his five-month sentence before certiorari was granted. More specifically, the question was whether any live controversy remained on which the Supreme Court's judgment could operate.

Rule

A federal court lacks power to decide moot questions or give advisory opinions that cannot affect the rights of the litigants. When a contempt sentence has been fully served and expired, the case is moot unless the judgment still carries further legal penalties or disabilities, or otherwise continues to operate in a way that a court's decision can affect.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cleveland, a federal district court sentenced Nora Bennett to 45 days in jail for criminal contempt after she refused to answer questions before a grand jury. By the time her petition for review reached the court of appeals, she had fully served the sentence, and she identified no state or federal law imposing any additional legal disability from the contempt judgment.

Should the appellate court dismiss Nora's challenge as moot?

Explanation. A federal court may not decide moot questions or issue advisory opinions. Under the majority's rule, when a contempt sentence has been fully served and expired, the case is moot unless the judgment still carries further legal penalties or disabilities or otherwise continues to affect the litigants' rights. Here, Nora finished the sentence and showed no continuing legal consequence, so there is no effective relief the court can provide. (Derived from St. Pierre v. United States (1943).)