St. John v. Campbell

── St. John v. Campbell ── Court: Court of Appeals for the First Circuit Date: April 29, 2026 Category: General United States Court of Appeals For the First Circuit No. 25-1354 SANDRA NATASHA ST. JOHN, Petitioner, Appellant, v. ANDREA JOY CAMPBELL, Respondent, Appellee. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Indira Talwani, U.S. District Judge] Before Barron, Chief Judge, Lipez and Rikelman, Circuit Judges. Michael A. Ugolini for appellant. Tara L. Johnston, Assistant Attorney General, with whom Andrea Joy Campbell, Attorney General of Massachusetts, was on brief, for appellee. April 29, 2026  RIKELMAN, Circuit Judge. Sandra Natasha St. John served a decade in prison after a Massachusetts court convicted her of attacking and severely injuring two people. Following St. John's release, the federal government deported her to the Republic of Trinidad and Tobago, where she was born and lived for several years. St. John then filed a petition for a writ of habeas corpus, alleging that her original attorney performed so poorly that she was deprived of her federal constitutional right to effective assistance of counsel at her criminal trial. She named the Attorney General of Massachusetts as the respondent in her petition. The district court dismissed the petition for lack of jurisdiction, concluding that St. John was no longer in custody, as required by the habeas corpus statute. Because St. John was not in the custody of any Massachusetts state official when she filed her petition, we affirm. I. BACKGROUND A. Relevant Facts In the early morning of October 26, 2007, 26-year-old Latoya Pannell lay in bed with her two young children when someone entered her Springfield apartment and doused her with hot cooking oil. Pannell suffered severe burns on her face and upper body; the oil also burned one of her children. - 2 -  After a 2010 bench trial in which Pannell identified St. John as her assailant,1 the Massachusetts Superior Court convicted St. John of burglary, mayhem, assault and battery with a dangerous weapon, and two counts of reckless endangerment of a child.2 See Mass. Gen. Laws. ch. 266, § 14; id. ch. 265 §§ 14, 15A, 13L. The court then sentenced her to ten to eleven years in prison. The Massachusetts Appeals Court affirmed St. John's conviction, and the Supreme Judicial Court denied further review. See Commonwealth v. St. John, 969 N.E.2d 185 (Mass. App. Ct. 2012) (unpublished table decision), review denied, 972 N.E.2d 1057 (Mass. 2012) (table). In November 2013, while St. John was serving her sentence, an Immigration Judge (IJ) revoked her lawful permanent status in the United States because of her convictions. The IJ also ordered her removal from the country. Near the end of her sentence, St. John secured a different attorney, and, in September 2021, she moved for a new trial in the Superior Court. The thrust of her argument was that her new attorney had found evidence demonstrating not only her innocence but also the ineffectiveness of her trial counsel. 1 The government contended that St. John had the motive to harm Pannell because of the two women's competition over a man with whom both had children but who was incarcerated at the time of the attack. 2 St. John waived her right to a jury trial.