Christopher Michael Morgan v. Sheriff Artetet

CourtDistrict Court, S.D. New York
DecidedOctober 24, 2025
Docket1:25-cv-06147
StatusUnknown

This text of Christopher Michael Morgan v. Sheriff Artetet (Christopher Michael Morgan v. Sheriff Artetet) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christopher Michael Morgan v. Sheriff Artetet, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CHRISTOPHER MICHAEL MORGAN, Petitioner, 25-CV-6147 (LLS) -against- ORDER TO AMEND SHERIFF ARTETET, Respondent. LOUIS L. STANTON, United States District Judge: Petitioner, who is currently detained in the Orange County Jail, brings this pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254, challenging his possibly ongoing criminal proceedings in what is likely the New York Supreme Court, Orange County. By order dated September 26, 2025, the court granted Petitioner’s request to proceed in forma pauperis. For the reasons set forth below, the Court grants Petitioner 60 days’ leave to file a petition for habeas corpus under 28 U.S.C. § 2241 or an amended petition under Section 2254. STANDARD OF REVIEW The Court may entertain a petition for a writ of habeas corpus on “behalf of a person in custody pursuant to the judgment of a State court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). Under Rule 4 of the Rules Governing § 2254 Cases, the Court has the authority to review and dismiss a § 2254 petition without ordering a responsive pleading from the state, “[i]f it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.” Rules Governing § 2254 Cases, Rule 4; see Acosta v. Artuz, 221 F.3d 117, 123 (2d Cir. 2000). 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) (emphasis in original); 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 Petitioner uses the court’s form to file a petition for habeas corpus under 28 U.S.C. § 2254, but the information provided in it is exceedingly confusing. Although he lists his date of conviction and date of sentencing as “May 5th,” he states that he was “sentenced” to a “730 evaluation,” which the Court understands to be a reference to Article 730 of the New York Criminal Procedure Law, which provides for a psychological examination to determine whether a criminal defendant is mentally fit to stand trial.1 (ECF 1, at 1.) In response to the question on the petition form asking him to identify the crimes of which he was convicted, Petitioner writes, “Attempted murder robby 2d causes fizical injury 2 charges dissmissial time served 6 other charges [illegible] I never got too go too tha grand jury plus too original charges no grand jury.”

(Id.) Petitioner states that he did not appeal his “conviction.” He does allege, however, that he filed a petition for a writ of habeas corpus in the Orange County Supreme Court, in which he raised the following ground for relief: George Washington dad King Queen Vivian Washington husband American flag inventor plus inventing Jesus children tew to God in Jezojudahcana Jesajudah and Martha I invent month of March off of her name and my middle name plus

1 The Court quotes from the petition verbatim. All spelling, grammar, and punctuation are as in the original petition unless otherwise indicated. inventing Maritaliacana for Martha tew be a god and Meritaliacana for Martha child tew be god Martha Washington I mean I love. (Id. at 3.) Petitioner does not indicate any result of that submission. In this petition, Petitioner lists four grounds for relief: (1) “I am George Washington dad inventor of Washington last name Morgan Shay plus American flag and [illegible] for Martha Washington tew to god Maracanna Maritaliacana” (id. at 5); (2) “America flag inventor” (id. at 6.); (3) Every color haet medal inventor Banner attest I am a God hort shaped [illegible] silver dollar future” (id. at 8); and (4) “50 purple 4 leef [illegible] flag plus every color star on blue I’m trying tew invert flag” (id. at 9). In support of his grounds, Petitioner alleges facts such as, “Lack of timely minutes for 6 charges lack of grand jury lack of preliminary hearing lack of arrainment 2 charges got

preliminary and arrainment but no grand jury then 2 month later 6 new charges indictment with no grand jury [illegible] and lawyer I didn’t want told me not tew talk.” (Id. at 8.) Petitioner checks boxes on the petition form to indicate that he did not exhaust any of his grounds for relief in the state court. Petitioner does not state the relief that he seeks. (See id. at 14.) DISCUSSION A. Status of Petitioner’s criminal proceedings Although Petitioner brings his claims using a Section 2254 form petition, it is unclear whether he has been convicted. Section 2254 does not apply in cases where a defendant has not been convicted. Section 2254 is the proper vehicle to challenge a state court conviction when the petition is brought by an individual who is in custody pursuant to a judgment of conviction. See

28 U.S.C. § 2254(a) (federal courts have jurisdiction to hear a Section 2254 petition filed on “behalf of a person in custody pursuant to the judgment of a State court”). If a judgment of conviction has not been entered in Petitioner’s case, he cannot challenge his criminal proceedings in a Section 2254 petition. A habeas corpus petition brought under 28 U.S.C. § 2241 is the proper vehicle to challenge the constitutionality of pretrial detention. See, e.g., Taylor v. New York City, No. 20- CV-5036 (MKV), 2020 WL 4369602, at *1 (S.D.N.Y. July 30, 2020) (construing claim by

pretrial detainee seeking release due to COVID-19 exposure as arising under Section 2241 (citing Braden v. 30th Jud. Cir. Ct. of Kentucky, 410 U.S. 484, 494-95 (1973))). Here, it is unclear whether Petitioner has been convicted. He appears to state that the trial court directed him to undergo an examination under Article 730 of the New York Criminal Procedure Law, which suggests his criminal proceedings may be ongoing. Petitioner also fails to state the relief he is seeking. The Court grants Plaintiff leave to file an amended petition that states whether he is challenging a final judgment of conviction under Section 2254, or whether he is seeking to challenge his pretrial detention in a petitioner under Section 2241. B. Rule 2 The petition, in its current state, does not specify the federal grounds upon which habeas

corpus relief is sought or the facts that support those grounds.

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