Fredricks v. Comstock

CourtDistrict Court, S.D. New York
DecidedAugust 26, 2024
Docket1:24-cv-03135
StatusUnknown

This text of Fredricks v. Comstock (Fredricks v. Comstock) 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
Fredricks v. Comstock, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK NIGEL FREDRICKS, Petitioner, 24-CV-3135 (LTS) -against- ORDER TO AMEND COMSTOCK, Superintendent, Respondent. LAURA TAYLOR SWAIN, Chief United States District Judge: Petitioner Nigel Fredricks, who is currently incarcerated at Coxsackie Correctional Facility, brings this pro se petition for a writ of habeas corpus under 28 U.S.C. § 2241. On March 15, 2024, Petitioner was granted leave to proceed in forma pauperis (“IFP”). For the following reasons, the Court designates Petitioner’s submission as a petition for a writ of habeas corpus under 28 U.S.C. § 2254, and grants him 60 days’ leave to file an amended petition. 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 Section 2254 Cases, the Court has the authority to review and dismiss a Section 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 Section 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 originally filed this petition in the United States District Court for the Northern District of New York. Because it was unclear what exactly Petitioner was challenging, on April 3, 2024, that court directed Petitioner to file an affirmation clarifying his intentions. (ECF 15.) On April 11, 2024, the Northern District received from Petitioner a letter in which he referred to his “parole status being revoke[d on] May 20, 2022 without a new parole violation for a new charge that occurred in Rikers Island.” 1 (ECF 17, at 1.) Petitioner also agreed that the case could be transferred to this court. On April 18, 2024, the Northern District transferred the action to this court. (ECF 18.) Petitioner brings this action using the Northern District’s Section 2241 petition form. He asserts that on March 12, 2022, after his parole was revoked, he was sentenced in the Manhattan

Supreme Court. (ECF 1, at 1.) Petitioner contends that the New York State Department of Corrections and Community Supervision (“DOCCS”) is improperly calculating his sentence under New York Penal Law § 70.30 ‒ a statutory provision on how to calculate terms of imprisonment. Petitioner incorrectly refers to several civil cases that he had filed in federal courts as appeals of the alleged miscalculation of his sentence. For example, he indicates that a prior Northern District case and its appeal, Fredricks v. I.R.C. Entity D.O.C., No. 23-CV-0112

1 The Court quotes from Petitioner’s submissions verbatim. All spelling, grammar, and punctuation are as in the originals unless noted otherwise. (N.D.N.Y. Sept. 19, 2023), appeal dismissed, No. 23-CV-7197 (2d Cir. June 18, 2024), were his first and second appeals of the issue he is raising in this habeas corpus petition.2 (ECF 1, at 2-3.) Petitioner further refers to a prior habeas corpus petition under 28 U.S.C. § 2254 that he filed in this court in 2022, Fredericks v. Warden Auburn C.F., No. 22-CV-3968 (LTS) (S.D.N.Y. Sept. 20,

2022), as a motion under 28 U.S.C. § 2255, in which he raised the same issues he brings in this action.3 (Id. at 4.) Petitioner attaches to the petition handwritten statements, in which he contends that New York Penal Law § 70.30 is unconstitutionally vague, along with a copy of a 1947 Supreme Court of Florida’s decision, Locklin v. Pridgeon, 158 Fla. 737 (Fla. 1947), which held that a statutory provision was unconstitutionally vague. (ECF 1, at 10-13.) In a statement captioned “Grounds Raised,” Petitioner writes, According to [DOCCS] changes has been made to my time calculation by stateing Penal Law 70.30 of dedacting allmost four and half years but fail to indicate nothing been imposed by the judge and I’ve been revoke so it would be nearly impossible to owe allmost four and half years on P.R.S. (ECF 1-2, at 1.) Petitioner seeks immediate release from DOCCS custody.

2 In Fredricks v. I.R.C. Entity D.O.C., No. 23-CV-0112, Petitioner sought damages for alleged miscalculation of his sentence. The Northern District determined that Petitioner is barred under 28 U.S.C. § 1915(g), from filing any new federal civil action IFP while he is a prisoner, and the Second Circuit dismissed the appeal as “lack[ing] an arguable basis either in law or in fact.” Fredricks v. I.R.C. Entity D.O.C., No. 23-CV-0112 (N.D.N.Y. Sept. 19, 2023), appeal dismissed, No. 23-CV-7197 (2d Cir. June 18, 2024). 3 In Fredericks v. Warden Auburn C.F., No. 22-CV-3968 (LTS), Petitioner seemingly sought to challenge his state court conviction but did not set forth clear grounds for relief or show exhaustion of state court remedies. The Court, after granting Petitioner 60 days’ leave to file an amended petition, dismissed the case because Petitioner did not file an amended petition as directed. Id., ECF 10. DISCUSSION A. Designation of Application as Section 2254 Petition The Court construes Petitioner’s submission as a petition for a writ of habeas corpus under 28 U.S.C. § 2254 because his assertion that DOCCS miscalculated his state court sentence is a challenge to the execution of his sentence. The proper vehicle for such a challenge is a petition brought under Section 2254, not Section 2241. See Cook v. N.Y. State Div. of Parole, 321

F.3d 274, 278-79 (2d Cir. 2003); see also Preiser v. Rodriguez, 411 U.S. 475, 500 (1973) (challenges to the validity of prison administrative actions that affect the fact or length of the state convicted prisoner’ s confinement are properly brought under Section 2254). If Petitioner does not want to pursue relief under Section 2254, he must 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); Cook, 321 F.

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Castro v. United States
540 U.S. 375 (Supreme Court, 2003)
Acosta v. Artuz
221 F.3d 117 (Second Circuit, 2000)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Locklin v. Pridgeon
30 So. 2d 102 (Supreme Court of Florida, 1947)
Bottom v. Goord
756 N.E.2d 55 (New York Court of Appeals, 2001)
Castro v. Rivera
69 A.D.3d 1000 (Appellate Division of the Supreme Court of New York, 2010)

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Bluebook (online)
Fredricks v. Comstock, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fredricks-v-comstock-nysd-2024.