DeJesus v. Royce

CourtDistrict Court, S.D. New York
DecidedJanuary 2, 2025
Docket1:22-cv-07212
StatusUnknown

This text of DeJesus v. Royce (DeJesus v. Royce) 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
DeJesus v. Royce, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- X : JAIME DEJESUS, : : Petitioner, : 22-CV-7212 (JMF) : -v- : : OPINION AND ORDER MARK ROYCE, Acting Superintendent, Green Haven : Correctional Facility, : : Respondent. : : ---------------------------------------------------------------------- X

JESSE M. FURMAN, United States District Judge: Jaime DeJesus was convicted of murder in the second degree after a jury trial in New York Supreme Court and sentenced to an indeterminate term of imprisonment between twenty- five years to life. He now petitions, pursuant to 28 U.S.C. § 2254, for the writ of habeas corpus. See ECF No. 1 (“Pet.”). In his Petition, DeJesus argues that (1) the trial court erred when it admitted certain identification testimony without an evidentiary hearing or additional foundation testimony; (2) the trial court erred when it admitted historical cell site evidence obtained without a warrant; (3) the trial court erred when it admitted graphic photographs of the victim’s injuries; (4) his counsel was constitutionally ineffective for failing to challenge the prosecution’s evidence and investigate exculpatory leads; (5) he was denied due process on account of prosecutorial misconduct; (6) he is legally, factually, and actually innocent; and (7) his sentence was excessive. See Pet. 27-31; see also ECF No. 25 (“Resp’t’s Mem.”), at 3-4. For the reasons that follow, DeJesus’s Petition is dismissed. BACKGROUND In 2013, DeJesus was arrested and indicted by a grand jury on several charges relating to the death of Alexis Rodriguez, including second-degree murder. Resp’t’s Mem. 2, 6. The proof against him at trial included surveillance footage of the murder and call detail reports and

historical cell site data for DeJesus’s cell phone. See id. at 4-9. In addition, the trial court admitted identification testimony from Natalie Ramos, who was standing next to the victim at the time of the murder, id. at 21-22, and from Ashanty Rodriguez, the victim’s sister and DeJesus’s acquaintance, albeit with an instruction to the jury that she “was only giving [her] opinion” that DeJesus was the person depicted in the surveillance video, see id. at 25; see also People v. DeJesus, 143 N.Y.S.3d 356, 356 (1st Dep’t 2021). DeJesus did not present any evidence in his defense. See Resp’t’s Mem. 9. On November 19, 2015, the jury found DeJesus guilty of murder in the second degree, and the trial court sentenced him to an indeterminate term of imprisonment between twenty-five years and life. See id. at 3. DeJesus appealed to the Appellate Division, First Department. See DeJesus, 143

N.Y.S.3d at 356. As relevant here, DeJesus argued that the trial court had erred when it had (1) admitted Ramos’s and Ashanty Rodriguez’s identification testimony without an evidentiary hearing or additional foundation testimony; (2) admitted historical cell site data even though it had been obtained without a search warrant; (3) admitted graphic photographs of the victim’s injuries; and (4) allowed the prosecutor to make “repeated inflammatory comments” during summation. ECF Nos. 25-1–25-6 (“Resp’t’s App’x”), at A38-83. DeJesus also argued that his indeterminate sentence of imprisonment between twenty-five years and life was excessive. See id. at A84-85. By opinion dated March 23, 2021, the Appellate Division affirmed. First, the court held that the trial court had “properly denied [DeJesus’s] motion for a[n evidentiary] hearing regarding [Ramos’s] identification testimony,” noting that Ramos’s “viewing of a surveillance videotape of the crime, at which she was present, and identification of [DeJesus], whom she had

known for years from the neighborhood, as the shooter, did not constitute an identification procedure within the meaning of [New York Criminal Procedure Law (‘CPL’)] 710.30,” which requires pretrial notice of certain identification testimony. DeJesus, 143 N.Y.S.2d at 357. The court also held that DeJesus had failed to “establish any basis for excluding [Ashanty Rodriguez’s] testimony” and that there was “no error in . . . allowing [her] to express an opinion.” Id. at 357-58. Second, the court declined to review DeJesus’s arguments regarding the historical cell site data on the ground that he had failed to preserve them in the trial court. Id. at 358. In any event, the court held, “any error was harmless in light of the overwhelming direct and circumstantial evidence, derived from multiple sources.” Id. Third, the court held that the photographs of the victim “were relevant to establish the victim’s injuries and . . . that the victim

was shot at close range,” and that, in any case, “there was nothing depicted in the photos, or stated in the prosecutor’s summation, that was so inflammatory as to require reversal.” Id. Finally, the court stated that it “perceive[d] no basis for reducing the sentence.” Id. DeJesus then unsuccessfully sought leave to appeal to the Court of Appeals. See 37 N.Y.3d 964 (2021); see also Resp’t’s App’x A198-211. DeJesus then moved to vacate his conviction pursuant to CPL § 440.10, claiming actual innocence, ineffective assistance of counsel, and prosecutorial misconduct. See id. at A264-68. In support of his claim of actual innocence, DeJesus submitted affidavits from Lester Classen, DeJesus’s half-brother who was also arrested as a suspect in the murder case, and Gervacio Rosa, Classen’s cousin whose house was searched by the police during its investigation of the murder. See id. at A541-44. Classen’s affidavit stated that Classen and DeJesus had been in Classen’s apartment at the time of the shooting. See id. at A541-43. Rosa’s affidavit stated that police officers had “entered [his] home” and his wife’s apartment “without showing [him] a

warrant for anything” and recovered a wallet that was left at his wife’s apartment. Id. at A544. In response, the People submitted an affidavit from DeJesus’s trial counsel stating that, “had [Classen] informed [him] of an alibi, [he] certainly would have investigated that alibi.” Id. at A574. With respect to the claim of ineffective assistance of counsel, DeJesus argued that his trial attorney had failed to interview Classen (who would have provided alibi evidence); failed to point out an inconsistency between the 911 caller’s description of the shooter and the surveillance footage; failed to seek a missing-witness charge for Jeremy Colon, a witness to the murder who had initially denied that he knew the shooter but later identified DeJesus; failed to retain a cell site expert who would have explained that DeJesus had lived in the neighborhood at the time; and failed to challenge the wallet’s chain of custody. See id. at A265-66. Finally, with

respect to his claim of prosecutorial misconduct, DeJesus argued that the prosecution presented false testimony by Terence Munnelly, a detective who had claimed that the wallet was recovered from DeJesus’s person during his arrest. See id. In a written opinion dated April 18, 2023, the New York Supreme Court denied DeJesus’s motion without a hearing. See Resp’t’s App’x A579-87.1 The court rejected DeJesus’s claim of actual innocence, noting that DeJesus had “fail[ed] to demonstrate why the

1 DeJesus filed his Petition here while his CPL § 440.10 motion was still pending. Accordingly, the Court granted his request for a stay pursuant to Rhines v. Weber, 544 U.S. 269, 278 (2005). See ECF No. 9. On January 23, 2024, after the Appellate Division denied DeJesus’s appeal from the New York Supreme Court’s denial of his CPL 440.10. motion, the Court granted DeJesus’s motion to lift the stay. See ECF No. 19.

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DeJesus v. Royce, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dejesus-v-royce-nysd-2025.