Kelton Habeas Petition Dismissed, Probation Conditions Not Cognizable

Fri, 24 Apr 2026 01:09:27 +0000
Criminal Justice

The US District Court for the District of Idaho dismissed Courtney Anne Kelton's petition for writ of habeas corpus or quo warranto challenging intensive probation supervision conditions including electronic monitoring. The court held that quo warranto cannot be brought by a private individual and that habeas corpus relief under 28 U.S.C. § 2254 is unavailable where a petitioner challenges the conditions of probation rather than the fact or duration of confinement. The court found the petition subject to summary dismissal under Habeas Rule 4 because the petition and attached exhibits plainly showed Kelton was not entitled to relief. Claims challenging probation conditions must instead be raised under 42 U.S.C. § 1983.