Lackawanna County District Attorney v. Coss

Summary

The Supreme Court held that a state prisoner generally may not use a 28 U.S.C. § 2254 petition to collaterally attack an expired prior conviction that was used to enhance a current sentence, extending its earlier § 2255 ruling in Daniels v. United States to the state-habeas context; once a conviction is no longer open to direct or collateral attack, it may be regarded as conclusively valid. The Court recognized an exception where the enhancing conviction was rendered in complete absence of appointed counsel in violation of Gideon, and it reserved whether further exceptions might exist for state-process failures or newly discovered evidence of innocence. It then concluded that the lower courts clearly erred in finding that Coss's 1986 convictions actually affected his 1990 sentence, because the sentencing court had excluded them from his prior record score and would have imposed the same sentence anyway. Justice Souter, joined by Justices Stevens and Ginsburg, dissented on the ground that the adverse-effect issue was neither adequately raised below nor properly resolved in the first instance by the Court, and Justice Breyer dissented because the harmless-enhancement question was unbriefed and should have been remanded.