Calhoun v. Colorado Attorney General, No. 13-1047 (10th Cir. 2014)
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Pro se appellant Ronald Calhoun appealed the district court's dismissal of his habeas corpus petition. The district court held that appellant was not "in custody," as required to invoke the jurisdiction of the federal courts. Appellant argued he was in custody because he must register as a sex offender. The Tenth Circuit issued a certificate of appealability on whether appellant's ongoing registration obligations under Colorado’s Sex Offender Registration Act satisfied the custody requirement of section 2254. Upon review, the Tenth Circuit affirmed the district court’s dismissal for lack of jurisdiction.
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