Escribano v. United States

CourtDistrict Court, S.D. New York
DecidedApril 18, 2022
Docket1:22-cv-03010
StatusUnknown

This text of Escribano v. United States (Escribano 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
Escribano v. United States, (S.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ZAIE ESCRIBANO, Movant, 22-CV-3010 (LTS)

-against- 16-CR-826-7 (LTS) UNITED STATES OF AMERICA, ORDER Respondent. LAURA TAYLOR SWAIN, Chief United States District Judge: Movant Zaie Escribano, who is currently incarcerated in the United States Penitentiary Hazelton, in Bruceton Mills, West Virginia, filed a letter in which he challenges the legality of his sentence entered in United States v. Escribano, No. 16-CR-0826-7 (S.D.N.Y. Nov. 2, 2018). Escribano asks the Court to construe his letter as an unspecified motion. As set forth below, the Court construes Escribano’s letter as a motion under 28 U.S.C. § 2255 to vacate his conviction or sentence, grants Escribano 60 days leave to file an amended Section 2255 motion, and directs him to state facts demonstrating that his motion is timely or that the doctrine of equitable tolling should apply in this case. 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 § 2255 motion before directing an answer “[i]f 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 4(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 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 (citing Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir. 1983)). BACKGROUND Escribano seeks to challenge his November 2, 2018, judgment of conviction in which he pleaded guilty to possession of a firearm during a crime of violence. See Escribano, ECF 1:16- CV-0826, 230. The Court sentenced Escribano to 84 months’ imprisonment to run consecutively to an undischarged term of imprisonment imposed in a criminal case from 2016, rendered in a Pennsylvania state court, followed by 5 years’ supervised release. Escribano did not appeal his conviction.

On April 12, 2022, the Court received a letter from Escribano, dated April 3, 2022, which Escribano describes as a motion, and in which he alleges that his conviction under Section 924(c)(A)(1) for possession of a firearm during a crime of violence should be vacated “[d]ue to new rulings by the Supreme Court [which] found that a Hobbs Act Robbery Conspiracy is not a crime of violence.” (ECF 1, at 1.) He argues that since his Section 924(c) conviction is “directly stemming from that conspiracy it has no merit to stand.” (Id.) Escribano asks the Court to vacate his conviction and appoint him counsel to further assist him in this matter. The Clerk of Court opened the letter as a new civil action brought under Section 2255. DISCUSSION Designation of Application as Motion Under 28 U.S.C. § 2255 Escribano’s application must be construed as a motion for relief under 28 U.S.C. § 2255 because he seeks to vacate his conviction. See Jiminian v. Nash, 245 F.3d 144, 146-47 (2d Cir. 2001) (Section 2255 “is generally the proper vehicle for a federal prisoner’s challenge to his

conviction and sentence”). If Escribano does not want to pursue relief under Section 2255, he may notify the Court in writing within 60 days 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). Escribano will have one opportunity within the limitations period (see subdivision “C” below) for a full adjudication of his claims. If Escribano does not inform the Court of his intent within 60 days, the application will remain designated as a motion under 28 U.S.C. § 2255. The Court Grants Escribano Leave to File an Amended Section 2255 Motion Under Rule 2 of the Rules Governing Section 2255 Proceedings, a Section 2255 motion must (1) specify all the grounds for relief available to the moving party; (2) state the facts supporting each ground; (3) state the relief requested; (4) be printed, typewritten, or legibly handwritten; and (5) be signed under penalty of perjury by the movant or by a person authorized to sign it for the movant. A motion must permit the Court and the 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 petition may be adjudicated. Escribano’s letter does not conform to the requirements of Rule 2 because it is unclear whether he raises all his grounds in the letter. He also does not sign the letter under the penalty of perjury. The Court therefore grants Escribano 60 days from the date of this order to file an amended motion that complies with Rule 2. Timeliness In addition, Escribano’s Section 2255 motion appears 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. § 2255(f). Escribano’s conviction became final on or around January 31, 2019, at the expiration of the 90-day period to file a petition for a writ of certiorari with the Supreme Court. See Sup. Ct. R. 13.1. If the Court accepts the date on the letter, April 3, 2022, as the filing date pursuant to Rule 3 of the Rules Governing Section 2255 Proceedings,1 Escribano’s motion was filed more than three years and two months after his conviction became final. The Court understands Escribano’s reference to “new rulings” in which the Supreme Court “found that a Hobbs Act Robbery Conspiracy is not a crime of violence” to be a reference

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Escribano v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/escribano-v-united-states-nysd-2022.