Brown v. State of New York

• Court: Court of Appeals for the Second Circuit
• Decided: October 16, 2025
• Docket: 24-1910
• Status: Unpublished

Opinion

24-1910 Brown v. State of New York

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 16th day of October, two thousand twenty-five.

Present:

BARRINGTON D. PARKER, SUSAN L. CARNEY, WILLIAM J. NARDINI, Circuit Judges. ____________________________________

LEON A. BROWN, JR.,

Petitioner-Appellant,

v. 24-1910

STATE OF NEW YORK,

Respondent-Appellee.

_____________________________________

For Petitioner-Appellant: Leon A. Brown, Jr., pro se, Las Vegas, NV

For Defendants-Appellants: Michelle Maerov, Senior Assistant Attorney General of Counsel, Barbara D. Underwood, Solicitor General, Ira M. Fienberg, Deputy Solicitor General, for Letitia James, Attorney General of the State of New York, New York, NY 1 Appeal from a judgment of the United States District Court for the Northern District of

New York (Lawrence E. Kahn, District Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Petitioner Leon A. Brown, Jr., appeals from an order of the United States District Court for

the Northern District of New York (Lawrence E. Kahn, District Judge) entered on June 24, 2024,

dismissing his petition for a writ of error coram nobis. In 1992, Brown pleaded guilty to second-

degree sexual abuse in New York state court. He is no longer imprisoned or on probation, but is

subject to New York’s Sex Offender Registration and Notification Act. In July 2023, he filed a

motion for a writ of error coram nobis in state court, which was denied in August 2024. In April

2024, he filed this federal petition for a writ of error coram nobis in the Northern District of New

York. The petition challenges the validity of his 1992 state conviction on the ground that he

received ineffective assistance of counsel. The petition also challenges the validity of his

placement on New York’s sex offender registry. The district court dismissed Brown’s petition

sua sponte, concluding that it lacked jurisdiction to grant coram nobis relief with respect to a state

court judgment. Brown appealed. We assume the parties’ familiarity with the case.

This Court “reviews de novo the legal standards that the district court has applied but

reviews for abuse of discretion the court’s ultimate decision to deny the writ.” Doe v. United

States, 915 F.3d 905, 909 (2d Cir. 2019). 1 The district court properly concluded that it lacked

jurisdiction to grant Brown’s petition for a writ of coram nobis, because “federal courts lack

jurisdiction to grant such writs with respect to state court judgments.” Ogunwomoju v. United

1 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted. 2 States, 512 F.3d 69, 75 (2d Cir. 2008); see also Finkelstein v. Spitzer, 455 F.3d 131, 133–34 (2d

Cir. 2006). We have explained that “the writ traditionally has been utilized by courts to correct

errors within their own jurisdiction.” Ogunwomoju, 512 F.3d at 75 (emphasis added); see also

28 U.S.C. § 1651(a) (“The Supreme Court and all courts established by Act of Congress may issue

all writs necessary or appropriate in aid of their respective jurisdictions and agreeable to the usages

and principles of law.”) (emphasis added). Because the district court lacked jurisdiction to grant

the writ, it did not abuse its discretion in denying Brown’s petition.

We have considered Brown’s remaining arguments and find them unpersuasive.

Accordingly, we AFFIRM the judgment of the district court.

FOR THE COURT:

Catherine O’Hagan Wolfe, Clerk