Dottin v. United States

CourtDistrict Court, S.D. New York
DecidedDecember 10, 2024
Docket7:24-cv-09319
StatusUnknown

This text of Dottin v. United States (Dottin v. United States) 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
Dottin v. United States, (S.D.N.Y. 2024).

Opinion

GLEN ELECTRONICALLY FILED UNITED STATES DISTRICT COURT be SOUTHERN DISTRICT OF NEW YORK DATE FILED: □□□□ 0/2024 MARCEL DOTTIN, Movant, 24-CV-9319 (VB) -against- 21-CR-0757-1 (VB) UNITED STATES OF AMERICA, ORDER TO AMEND Respondent. VINCENT L. BRICCETTI, United States District Judge: Movant Marcel Dottin, currently incarcerated at FCI Ray Brook in Ray Brook, New York, filed a motion under 28 U.S.C. § 2255, seeking an extension of time to challenge the legality of his sentence entered in United States v. Dottin, No, 21-CR-0757-1 (VB) (S.D.N.Y. Feb. 17, 2023). For the following reasons, the Court construes Dottin’s motion as a substantive motion under Section 2255 and directs Dottin to file an amended motion by February 10, 2025. STANDARD OF REVIEW A prisoner in federal custody may bring a motion under 28 U.S.C,§ 2255 attacking his conviction or sentence on the grounds that it violates the Constitution or United States law, was imposed without jurisdiction, exceeds the maximum penalty, or is otherwise subject to collateral attack. 28 U.S.C. § 2255. Under Rule 4(b) of the Rules Governing § 2255 Proceedings, the Court has the authority to review and deny a Section 2255 motion before directing an answer “Calf it plainly appears from the motion, any attached exhibits, and the record of prior proceedings that the moving party is not entitled to relief.” Rules Governing § 2255 Proceedings, Rule A(b); see Acosta v. Nunez, 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 y. 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 (citing Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir. 1983)). BACKGROUND Ina judgment of conviction dated February 17, 2023, Dottin was convicted after pleading guilty to conspiracy to commit Hobbs Act robberies, Hobbs Act robbery, and brandishing a firearm in furtherance of a crime of violence. Dottin, ECF 7:21-CR-0747-2, 82. On December 2, 2024, the court received a motion from Dottin in which he requests an extension of time to file a Section 2255 motion.! (ECF 1.) In the motion, Dottin alleges facts in support of his request for

an extension of time and states that he is seeking to challenge his conviction under United States Supreme Court’s decision in United States v. Taylor, 596 U.S. 845 (2022),? DISCUSSION A. Designation of application as motion under 28 U.S.C. § 2255 Although Dottin submitted a Section 2255 form, he styles his submission as a motion for

an extension of time to file a Section 2255 motion. The Second Circuit has held that “a federal court lacks jurisdiction to consider the timeliness of a [habeas] petition until a petition is actually filed[,]” because prior to an actual filing, “there is no case or controversy to be heard[.]” Green v. United States, 260 F.3d 78, 82 (2d Cir. 2001); United States v. Leon, 203 F.3d 162, 164 (2d Cir.

| Dottin initiated this action by completing and submitting a Section 2255 form, a form created and issued by the Administrative Office of the United States Courts. He titles the motion as an “amended” motion. 2 In Zaylor, the Court held that attempted Hobbs Act robbery does not qualify as a crime of violence under the elements clause of the statutory definition of a crime of violence to support a felony conviction and enhanced sentence for using a firearm in furtherance of a crime of violence,

2000) (per curiam). However, “[w]here a motion, nominally seeking an extension of time, contains allegations sufficient to support a claim . . ., a district court is empowered, and in some instances may be required, . . . to treat that motion as a substantive motion for relief.” Green, 260 F.3d at 82. Here, because Dottin states that he is seeking to challenge his conviction pursuant to Taylor, the Court construes the submission as a substantive motion under Section 2255.3 B. Order to Amend Rule 2(b) of the Rules Governing Section 2255 Proceedings requires a motion to specify all of a movant’s available grounds for relief, setting forth the facts supporting each of the specified grounds and stating the relief requested. A motion must permit the Court and Respondent to comprehend both the movant’s grounds for relief and the underlying facts and legal theory supporting each ground so that the issues presented in the motion may be adjudicated. Here, Dottin’s submission, in which he requests an extension of time to file a Section 2255 motion, and which was opened as a Section 2255 motion, states a single ground for relief but it does not allege any facts supporting his grounds for relief. The submission therefore does not comply with Rule 2(b). Furthermore, while Dottin provides a single ground for relief, it is unclear whether he has additional grounds for relief he may wish to assert. Because Dottin has only one opportunity to bring a Section 2255 motion asserting all of the grounds on which he seeks relief from the judgment, the Court grants him an opportunity to

3 If Dottin does not want to pursue relief under Section 2255, he may notify the Court in writing by February 10, 2025, that he wishes to withdraw the application. See Castro v. United States, 540 U.S. 375, 383 (2003); Adams v. United States, 155 F.3d 582, 584 (2d Cir. 1998) (per curiam). Dottin will have one opportunity within the limitations period for a full adjudication of his claims. If Dottin does not inform the Court of his intent by February 10, 2025, the application will remain designated as a motion under Section 2255.

file an amended Section 2255 motion. In the amended Section 2255 motion, Dottin must provide the grounds for relief and the facts supporting all his grounds, so that the issues can be adjudicated. C. Timeliness As Dottin acknowledges, his Section 2255 application may be time-barred. A federal prisoner seeking relief under Section 2255 must generally file a motion within one year from the latest of four benchmark dates: (1) when the judgment of conviction becomes final; (2) when a government-created impediment to making such a motion is removed; (3) when the right asserted is initially recognized by the Supreme Court, if it has been made retroactively available to cases on collateral review; or (4) when the facts supporting the claim(s) could have been discovered through the exercise of due diligence. See 28 U.S.C.

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Related

Castro v. United States
540 U.S. 375 (Supreme Court, 2003)
Eric Adams v. United States
155 F.3d 582 (Second Circuit, 1998)
United States v. Luis G. Leon
203 F.3d 162 (Second Circuit, 2000)
Donald L. Moshier, Jr. v. United States
402 F.3d 116 (Second Circuit, 2005)
United States v. Taylor
596 U.S. 845 (Supreme Court, 2022)

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Dottin v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dottin-v-united-states-nysd-2024.