Darius Dubose v. Angel Quiros

CourtDistrict Court, D. Connecticut
DecidedFebruary 12, 2026
Docket3:25-cv-00271
StatusUnknown

This text of Darius Dubose v. Angel Quiros (Darius Dubose v. Angel Quiros) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Darius Dubose v. Angel Quiros, (D. Conn. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DARIUS DUBOSE, : Case No. 3:25-CV-271 (SVN) Petitioner, : : v. : : ANGEL QUIROS, : Respondent. : February 12, 2026

ORDER Before the Court is Respondent Angel Quiros’s motion to dismiss Petitioner Darius Dubose’s original petition for writ of habeas corpus brought under 28 U.S.C. § 2241. Mot. to Dis., ECF No. 27. For the reasons set forth below, the Court DENIES as moot Respondent’s motion to dismiss Petitioner’s original habeas petition, but DISMISSES Petitioner’s superseding amended habeas petition in light of the recent pleadings submitted by the parties. I. BACKGROUND Petitioner filed a petition for writ of habeas corpus under 28 U.S.C. § 2241 on February 20, 2025. Pet., ECF No. 1, at 1. Petitioner was a pretrial detainee when he filed this habeas petition. See id. The petition raised four claims, all asserting violations of Connecticut state law. See id. at 3–4. Specifically, Petitioner maintained that the State had not provided him with certain evidence under Conn. Gen. Stat. §§ 54-86a and 54-86c (Claims 1 and 2), that he had been denied the right to a speedy trial under Conn. Gen. Stat. § 54-82c (Claim 3), and that his case should have been dismissed, under Conn. Gen. Stat. §§ 54-82d and 54-56 (Claim 4). Id. The petition sought dismissal of Petitioner’s state charges, release from imprisonment, and a “[s]uper [i]njunction protecting [his] unalienable rights.” Id. at 4. The Court ordered Respondent to file a response to Petitioner’s habeas petition. See Order, June 5, 2025, ECF No. 26. Respondent complied by filing a motion to dismiss the habeas petition on June 10, 2025. Mot. to Dis., ECF No. 27. Petitioner, in turn, filed a motion for summary judgment on June 17, 2025, and a response to Respondent’s motion to dismiss on July 15, 2025. Mot. for Summ. J., ECF No. 28; Pet. Resp., ECF No. 32. Petitioner also filed a series of objections, affidavits, and notices after briefing concluded. See ECF Nos. 35–42.

On October 2, 2025, Petitioner pled “nolo contendere”1 to three criminal offenses in the underlying state criminal case he challenges in his original habeas petition.2 The state court sentenced Petitioner to a total of five years’ imprisonment, suspended after three years, and three years’ conditional discharge. See note 2. Petitioner’s expected release date is October 26, 2026.3 Because Petitioner’s nolo contendere plea in the underlying state criminal case appeared to foreclose the claims contained in his habeas petition, see Tollett v. Henderson, 411 U.S. 258, 266 (1973) (noting that a guilty plea “forecloses direct inquiry into the merits of claimed antecedent constitutional violations….”), the Court ordered the parties to submit briefs addressing whether Petitioner’s claims were still cognizable. See Order, January 8, 2026, ECF No. 43.

Respondent submitted a brief arguing that “[t]he petitioner’s pleas waived his ability to pursue relief on the claims raised in his petition.” Memo. of Law, ECF No. 49 at 1. Instead of

1Connecticut law “permits a defendant to enter a conditional plea of nolo contendere while preserving the right to appeal in certain specified circumstances, namely, the denial of a motion to dismiss or a motion to suppress that is dispositive of the case.” State v. Russo, 221 Conn. App. 729, 752–53 (2023) (footnote omitted). “A nolo contendere plea has the same effect as a guilty plea, but a nolo contendere plea cannot be used against the defendant as an admission in a subsequent criminal or civil case.” State v. Colon, 234 Conn. App. 265, 274 n.9 (2025) (internal quotation marks and citation omitted). 2 See State of Connecticut Judicial Branch, Criminal/Motor Vehicle Conviction Case Detail (No. A05D-CR23- 0191996-S), https://www.jud2.ct.gov/crdockets/CaseDetailDisp.aspx?source=Pending&Key=542505da-9677-413d- b110-961df6728240 (last accessed February 12, 2026). The Court may take judicial notice of content on this website. See Davis v. Guadarama, No. 3:24-CV-00278 (SFR), 2025 WL 1027998, at *1 n.1 (D. Conn. Mar. 13, 2025). 3See Department of Correction (“DOC”), Offender Information Search, https://www.ctinmateinfo.state.ct.us/detailsupv.asp?id_inmt_num=321480 (last accessed February 12, 2026). The Court may also take judicial notice of content on this website. See Taveras v. Semple, No. 3:15-CV00-531 (SALM), 2023 WL 112848, at *1 n.1 (D. Conn. Jan. 5, 2023) (taking judicial notice of Connecticut DOC offender information search). submitting a brief as ordered, Petitioner submitted several affidavits unrelated to the issue of his nolo contendere pleas, see Affidavits, ECF Nos. 44–47, and an amended petition for writ of habeas corpus. See Am. Pet., ECF No. 50.4 Petitioner’s amended habeas petition is markedly different than his original petition. The Petitioner states in it that he “was convicted in the Connecticut Superior Court …, under docket

number A05DCR230191996S, following the entry of a guilty plea on or about 08/26/2025 & 10/2/2025.” ECF No. 50 ¶ 1. Petitioner states that he is “currently in custody pursuant to that conviction and sentence.” Id. ¶ 2. And instead of asserting that his pretrial confinement violates state law, as he did in his original habeas petition, see ECF No. 1 at 3–4, Petitioner now “challenges the Constitutionality of the arrest, plea and conviction.” ECF No. 50 ¶ 3. Specifically, Petitioner now asserts that his guilty plea was unknowingly and involuntarily made, that he received ineffective assistance of counsel, and that the state court did not permit Petitioner to represent himself, all in violation of his constitutional rights. Id. ¶¶ 4–14. Petitioner now asks the Court to vacate his guilty plea and conviction, order his “immediate release,” and enter a “[s]uper

[i]njunction” against the State of Connecticut “to avoid his rights being violated again….” Id. at 4.5 Petitioner also filed an “Affidavit of Brief” that appears to elaborate on the claims in the amended petition. Aff., ECF No. 48.

4 Petitioner sought leave to respond to Respondent’s submission, but the Court denied this motion, as the briefing it requested was intended to be concurrent and Petitioner had chosen to file several other documents, but not a brief on the effect of the nolo contendere pleas, during the relevant period. See Mot. for Ext. of Time, ECF No. 51; Order, ECF No. 52. 5 In a handwritten addition to the certificate of service, Petitioner noted that the amended petition was being mailed to the Superior Court in Derby, Connecticut. See ECF No. 50 at 6. The caption of the amended petition makes clear, however, that he intended to file it in this court, the U.S. District Court for the District of Connecticut. II. DISCUSSION A. Amended Petition Before the Court can decide the pending motions, it must first determine which habeas petition is operative. See Wakefield v. Scott, No. 5:17-CV-115, 2019 WL 13271839, at *2 (D. Vt. Sept. 24, 2019) (first determining the operative complaint before deciding motion for judgment on

the pleadings). This analysis turns on whether Petitioner may amend his original habeas petition. The Rules Governing Section 2254 Cases do not address amendment of petitions. But “[t]he Federal Rules of Civil Procedure

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Tollett v. Henderson
411 U.S. 258 (Supreme Court, 1973)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
Raineri v. United States
233 F.3d 96 (First Circuit, 2000)
Eric Adams v. United States
155 F.3d 582 (Second Circuit, 1998)
Acosta v. Artuz
221 F.3d 117 (Second Circuit, 2000)
Mathilde Muniz v. United States
236 F.3d 122 (Second Circuit, 2001)
David Thai v. United States
391 F.3d 491 (Second Circuit, 2004)
Quint v. Commissioner of Correction
913 A.2d 1120 (Connecticut Appellate Court, 2007)
O'Hazo v. Bristol-Burlington Health District
599 F. Supp. 2d 242 (D. Connecticut, 2009)
Merle S. v. Commissioner of Correction
143 A.3d 1183 (Connecticut Appellate Court, 2016)
Pettaway v. National Recovery Solutions
955 F.3d 299 (Second Circuit, 2020)
United States v. Okafor
49 F. App'x 353 (Second Circuit, 2002)
State v. Russo
221 Conn. App. 729 (Connecticut Appellate Court, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Darius Dubose v. Angel Quiros, Counsel Stack Legal Research, https://law.counselstack.com/opinion/darius-dubose-v-angel-quiros-ctd-2026.