Greeman v. State of New York

CourtDistrict Court, S.D. New York
DecidedOctober 20, 2023
Docket1:22-cv-04300
StatusUnknown

This text of Greeman v. State of New York (Greeman v. State of New York) 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
Greeman v. State of New York, (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK EDWARD GREEMAN, Petitioner, 22-CV-4300 (AS) -against-

THE SUPERINTENDENT OF MEMORANDUM OPINION FISHKILLCORRECTIONAL FACILITY, AND ORDER Respondent.

ARUN SUBRAMANIAN, United States District Judge: On March 25, 2022, petitioner Edward Greeman filed a pro se petition for a writ of habeas corpus, pursuant to 28 U.S.C. § 2254. For the following reasons, Greeman’s petition is DENIED. BACKGROUND On January 23, 2020, a New York Supreme Court jury found Greeman guilty of 15 counts of second-degree criminal possession of a forged instrument, 9 counts of first-degree criminal tampering, and one count of second-degree criminal impersonation. See Dkt. 20 at 1187–95. He was sentenced to an aggregate indeterminate prison sentence of 5½ to 11 years. Id. at 1214–15. At Greeman’s trial, the government introduced evidence showing that, on multiple occasions between September 2017 and July 2018, Greeman jammed the credit card and bill slots of the MetroCard vending machines at the South Ferry subway station in Manhattan so that customers would be unable to purchase or add money to a MetroCard. Then, dressing as a Metropolitan Transit Authority (MTA) employee, Greeman collected payment from subway riders who were unable to purchase a MetroCard. Greeman let them into the subway either by opening the emergency gate or swiping them in with a tampered MetroCard. During three arrests, officers discovered MetroCards in Greeman’s possession that had been bent along the magnetic strip in a way that would allow a user to obtain a ride even if there was a zero balance on the card. See id. at 541–625. In February 2020, Greeman filed a pro se motion under CPL § 440.20, seeking to set aside his sentence. Dkt. 19 at 3–7. Greeman claimed that the sentence exceeded the maximum time permitted by statute. Id. at 6–7. In July 2020, Greeman filed a pro se motion under CPL § 440.10, arguing that the evidence at trial was insufficient to support his convictions for second-degree criminal possession of a forged instrument. Id. at 9–15. On October 27, 2020, Greeman’s motions were denied. Id. at 36. The court found that Greeman’s sentence was lawful and determined that any claim based on legal sufficiency needed to be raised on direct appeal. Id. at 37–39. Greeman then filed a pro se appeal in the Appellate Division, First Department. Id. at 42. As relevant here, Greeman argued that (1) his arrest was “Warrantless and Unlawful,” (2) the government exceeded the maximum time it had to prosecute the case under CPL § 30.30, (3) there was not legally sufficient evidence to support his convictions for second-degree criminal possession of a forged instrument because the government failed “to produce non-hearsay evidence or to perform a testing of the alle[g]ed forged instruments,” and (4) the government withheld exculpatory evidence from the grand jury, violating the Sixth Amendment. Id. at 218– 20. On November 18, 2021, the Appellate Division unanimously affirmed Greeman’s conviction. See People v. Greeman, 199 A.D.3d 530 (1st Dep’t 2021). Greeman subsequently filed a pro se application for leave to appeal to the New York Court of Appeals. Dkt. 19 at 296. The application requested review of the Appellate Division’s findings regarding his CPL § 30.30 claim and his sufficiency of the evidence claim. Id. at 297–98. On January 31, 2022, the Court of Appeals denied Greeman’s application. See People v. Greeman, 37 N.Y.3d 1161 (2022). On April 1, 2022, the Court of Appeals further denied Greeman’s motion for reconsideration. See People v. Greeman, 38 N.Y.3d 1008 (2022). Greeman, again proceeding pro se, filed a petition for a writ of habeas corpus in this Court, pursuant to 28 U.S.C. § 2254. Dkt. 2. The petition seeks relief on four grounds. First, Greeman claims that the arrest was warrantless and unlawful because officers arrested him at a garage “2 blocks away from [the] train station,” where they had “no jurisdiction to execute an arrest and no warrant.” Id. at 4. Second, Greeman claims that the government exceeded the 180-day maximum period permitted to prosecute the case under CPL § 180.80. Id. at 5. Third, Greeman claims that there was not legally sufficient evidence to support his convictions for second-degree criminal possession of a forged instrument because the government “failed to perform a test of the forged instruments as required by law” or “to validate the authenticity of the forged instruments.” Id. at 7. Finally, Greeman claims that the government withheld exculpatory evidence, in violation of Brady v. Maryland, 373 U.S. 83 (1963). Id. at 8. Greeman then filed a supplemental petition for a writ of habeas corpus. Dkt. 9. This amended petition asserts the same four grounds for relief with three clarifications. First, Greeman clarifies that ground one—that his arrest was unlawful—is based on CPL § 140.40. See id. at 5. Second, Greeman clarifies that ground two—that his prosecution exceeded New York’s speedy- trial law—is based on CPL § 30.30. See id. at 7.1 Finally, Greeman’s amended petition makes clear that ground four is based on the government’s alleged withholding of exculpatory evidence from the grand jury. Id. at 10.

1 CPL § 180.80 concerns the time the government has to indict someone arrested for a felony. CPL § 30.30 provides that the government must be ready for trial within “six months of the commencement of a criminal action wherein a defendant is accused of one or more offenses, at least one of which is a felony.”

2 LEGAL STANDARDS Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a state prisoner may challenge his convictions or sentence in federal court when “he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). A federal court may grant relief only for claims “adjudicated on the merits” in state court, and then only if the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” or was “based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” Id. § 2254(d). DISCUSSION I. Unlawful Arrest & Exculpatory Evidence Grounds one and four—that Greeman’s arrest was unlawful and that the government withheld exculpatory evidence—are procedurally defaulted. So the Court declines to review them on the merits. A federal court may not grant a § 2254 habeas petition “unless it appears that … the applicant has exhausted the remedies available in the courts of the State” or that there is either “an absence of available State corrective process” or “circumstances exist that render such process ineffective to protect the rights” of the prisoner. 28 U.S.C. § 2254(b)(1). “To satisfy § 2254’s exhaustion requirement, a petitioner must present the substance of the same federal constitutional claims that he now urges upon the federal courts to the highest court in the pertinent state.” Aparicio v. Artuz, 269 F.3d 78, 89–90 (2d Cir. 2001) (cleaned up).

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Aparicio v. Artuz
269 F.3d 78 (Second Circuit, 2001)
Jua Smith v. George Duncan
411 F.3d 340 (Second Circuit, 2005)
People v. Mattocks
908 N.E.2d 878 (New York Court of Appeals, 2009)
Brown v. Davenport
596 U.S. 118 (Supreme Court, 2022)

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Bluebook (online)
Greeman v. State of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greeman-v-state-of-new-york-nysd-2023.