Anjelu Sajetta v. Maginley-Liddie

District Court, S.D. New York·Decided December 10, 2025·No. 1:25-cv-05718·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ANJELU SAJETTA, Petitioner, 25-CV-5718 (LLS) -against- ORDER TO AMEND MAGINLEY-LIDDIE, Respondent. LOUIS L. STANTON, United States District Judge: Petitioner, currently incarcerated at Rikers Island, paid the fee to bring this pro se petition for a writ of habeas corpus under 28 U.S.C. § 2241. For the reasons set forth below, the Court directs Petitioner to file an amended petition within 60 days of the date of this order. STANDARD OF REVIEW The Court may entertain a petition for a writ of habeas corpus from a person in custody challenging the legality of his detention on the ground that “[h]e is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c)(3). The Court has the authority to review the petition and “award the writ or issue an order directing the respondent to show cause why the writ should not be granted, unless it appears from the application that the applicant or person detained is not entitled [to such relief].” 28 U.S.C. § 2243. The Court is obliged, however, to construe pro se pleadings liberally and interpret them “to raise the strongest arguments they suggest.” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted); see Green v. United States, 260 F.3d 78, 83 (2d Cir. 2001). Nevertheless, a pro se litigant is not exempt “from compliance with relevant rules of procedural and substantive law.” Triestman, 470 F.3d at 477 (quoting Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir. 1983)). BACKGROUND The following facts are taken from the petition and the more than 300 pages of attachments, most of which are documents from Petitioner’s state-court litigation. (See ECF 1 at 13-328.) (ECF 1 at 82-93.) Petitioner is in pretrial detention, having been charged with Arson in the Third Degree and Reckless Endangerment in the Second Degree under New York County

Indictment No. 72641/2023. (ECF 1 at 82.) Petitioner sought habeas corpus relief in the state trial court;1 on July 17, 2024, the trial court denied the habeas petition on procedural and substantive grounds; the Appellate Division affirmed the denial of the writ on March 20, 2025, and denied re-argument and leave to appeal on July 1, 2025. (Id.) Petitioner alleges in this petition that: the prosecution in his ongoing criminal proceedings made false statements in court and “misled the court to induce a wrongful decision”; the prosecution has not complied with the speedy trial provisions of the Interstate Agreement on Detainers, New York Crim. Proc. L. 580.20, “resulting in a loss of jurisdiction”; and he has been denied effective legal representation and access to discovery. (Id. at 5.) After Petitioner filed this petition, he filed a motion for pro bono counsel and a motion to expedite this matter. (ECF 3, 8.)

DISCUSSION In Younger v. Harris, 401 U.S. 37 (1971), the Supreme Court held that a federal court may not enjoin a pending state court criminal proceeding in the absence of special circumstances suggesting bad faith, harassment, or irreparable injury that is both serious and immediate. Id. at 53-54; see also Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 72 (2013) (“Younger exemplifies one class of cases in which federal-court abstention is required: When there is a . . . pending state

1 Counsel filed the habeas corpus petition on Petitioner’s behalf, but Petitioner has otherwise proceeded pro se in the collateral litigation. criminal proceeding, federal courts must refrain from enjoining the state prosecution.”); Gristina v. Merchan, 131 F.4th 82, 86-87 (2d Cir. 2025) (“The Younger abstention doctrine embodies the longstanding public policy against federal court interference with state court proceedings.” (internal quotation marks and citation omitted)); Davis v. Lansing, 851 F.2d 72, 76 (2d Cir. 1988)

(holding that “[t]here is no question that [an] ongoing prosecution implicates important state interests[.]”). Bad faith or harassment exists when the party bringing the state court action has “no reasonable expectation of obtaining a favorable outcome.” Homere v. Inc. Vill. of Hempstead, 322 F. Supp. 3d 353, 368 (E.D.N.Y. 2018) (quoting Cullen v. Fliegner, 18 F.3d 96, 103 (2d Cir. 1994)); see also Kugler v. Helfant, 421 U.S. 117, 126 n.6 (1975) (noting that bad faith under Younger “generally means that a prosecution has been brought without a reasonable expectation of obtaining a valid conviction”); Diamond “D” Construction Corp. v. McGowan, 282 F.3d 191, 199 (2d Cir. 2002) (holding that the bad faith exception arises when “the state proceeding was initiated with and is animated by a retaliatory, harassing, or other illegitimate motive”);

DeMartino v. N.Y. State Dep’t of Labor, 167 F. Supp. 3d 342, 355-56 (E.D.N.Y. 2016) (holding that plaintiff’s allegations that the state administrative charges against him were based on defendant’s false statements did not “serve as the factual predicate for a plausible finding of bad faith”). Because a “pending state court prosecution ordinarily provides the accused ‘a fair and sufficient opportunity for vindication of federal constitutional rights,’” Nazer v. Warden at Rikers Island, No. 24-CV-5226 (LTS), 2024 WL 4109081, at *1 (S.D.N.Y. Aug. 26, 2024) (quoting Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006)), federal courts routinely decline to entertain habeas petitions filed by defendants who are in the midst of ongoing state criminal proceedings. See, e.g., Jordan v. Bailey, 570 F. App’x 42, 44 (2d Cir. 2014) (declining to consider a Section 2241 petition on the merits pursuant to Younger); Jones v. Walker, No. 22-CV- 993 (LTS), 2022 WL 623584, at *2 n.2 (S.D.N.Y. Mar. 3, 2022) (“Where a pretrial detainee challenges his custody in a habeas corpus petition brought under § 2241, courts have applied the

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