The U.S. Supreme Court case Randy G. Spencer v. Mike Kemna, Superintendent, Western Missouri Correctional Center et al., 1997 revolved around the issue of mootness in relation to habeas corpus petitions filed by prisoners who have been released on parole before their cases could be heard in court. The petitioner, Randy G. Spencer was a former inmate who had challenged his prison disciplinary proceedings that resulted in loss of good-time credits and extended his incarceration period but was paroled during the pendency of his appeal process making it moot according to lower courts' rulings. However, he argued that collateral consequences from these disciplinary actions still existed even after release such as affecting future parole decisions or reincarceration for violations which should allow him to continue with the case despite being out on parole now. The Supreme Court held that speculative collateral consequences are not sufficient to overcome mootness doctrine and since there were no concrete evidence showing how these past disciplinary records would affect him negatively post-release; hence they dismissed his petition stating it has become moot due to lack of an ongoing 'case or controversy' as required under Article III section 2 clause 1 of US Constitution.

In the dissenting opinion for Randy G. Spencer v. Mike Kemna, Superintendent, Western Missouri Correctional Center et al., Justice Stevens argued that the Court's decision to dismiss Spencer's appeal as moot was incorrect and unjustified. He contended that a habeas petitioner’s claim does not become moot simply because he has been released from custody during his appeal process. The justice emphasized that collateral consequences of conviction can still exist even after release, which could include difficulties in finding employment or housing due to criminal records or potential enhancement of sentences for future crimes based on past convictions. Therefore, according to Justice Stevens' view, these possible repercussions should be enough reason not to consider such cases as moot upon release from prison.