Joseph Carson v. T. McGuinness

CourtDistrict Court, S.D. New York
DecidedDecember 10, 2025
Docket7:23-cv-06776
StatusUnknown

This text of Joseph Carson v. T. McGuinness (Joseph Carson v. T. McGuinness) 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
Joseph Carson v. T. McGuinness, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

JOSEPH CARSON,

Petitioner, No. 23-CV-6776 (KMK)

v. ORDER ADOPTING REPORT &

RECOMMENDATION T. McGUINNESS,

Respondent.

KENNETH M. KARAS, District Judge: Joseph Carson (“Petitioner”), pro se, filed a Petition for a Writ of Habeas Corpus (“Petition”) pursuant to 28 U.S.C. § 2254, challenging his conviction and sentence. (Dkt. No. 1.) Before the Court are Petitioner’s Objections to Magistrate Judge Judith C. McCarthy’s Report and Recommendation (“R&R”). (See Pet’r’s Objs. to R&R (“Obj.”) (Dkt. No. 30).) After reviewing the R&R and Petitioner’s Objections, the Court adopts the result recommended in the R&R and denies the Petition. I. Background The factual and procedural background of this case is set forth in Judge McCarthy’s thorough R&R and the Court assumes the Parties’ familiarity therewith. (See Carson v. McGuinness, No. 23-CV-6776, 2024 WL 5469225, at *1–4 (S.D.N.Y. Aug. 28, 2024) (hereinafter “R&R”); see also Report & Recommendation 2–4 (Dkt. No. 24).) The Court here summarizes the facts relevant to addressing Petitioner’s Objections to the R&R. A. Factual Background Petitioner sold narcotics to undercover police officers on October 30 and November 9, 2018. (Aff. of Andrew Kass in Opp’n ¶¶ 1–3 (Dkt. No. 12).) Police then searched Petitioner’s residence on December 7, 2018, finding narcotics, associated paraphernalia, and $7,400 in cash. (Id. ¶ 2.) On December 18, 2018, Petitioner was indicted on three counts of Criminal Possession of a Controlled Substance in the Fourth Degree. (Mem. of Law in Opp’n, Ex. 13-1, at 2–3 (Dkt. No. 13).) On April 22, 2019, the State filed a separate indictment for the controlled buys it conducted in October and November of 2018, charging Petitioner with three counts of Criminal

Sale of a Controlled Substance in the Third Degree, and three counts of Criminal Possession of a Controlled Substance in the Third Degree. (Id. at 10–11). In a superseding indictment on September 9, 2019, the state added numerous other counts relating to drug possession, sale, and use of drug paraphernalia. (Id. at 17–24.) As part of a plea agreement, Petitioner pleaded guilty to two counts of Attempted Criminal Sale of a Controlled Substance in the Third Degree and waived his right to appeal his convictions and sentence in exchange for the dismissal of the remaining counts of the superseding indictment and a favorable sentencing recommendation. (Aff. of Andrew Kass in Opp’n ¶¶ 4–5 (Dkt. No. 12).) At a January 27, 2020 hearing, the State affirmed it would “recommend 7 years in state

prison along with 3 years of post-release supervision” at sentencing. (Mem. of Law in Opp’n, Ex. 13-3, at 3 (Dkt. No. 13).) The trial court informed Petitioner it was prepared to “cap [its] sentence at 5 years in state prison to be followed by 2 years of post-release supervision” and would be willing to consider a lower sentence depending on the contents of Petitioner’s Presentence Investigation Report. (Id. at 4.) The trial court informed Petitioner that his guilty plea waived certain rights, including his “right to appeal and . . . some discovery rights.” (Id. at 5.) When asked if he would still like to plead guilty, Petitioner responded, “[y]es.” (Id.; see also id. at 12–13.) The court also advised Petitioner that the appellate waiver in his plea agreement did not mean he could not take an appeal—rather, Petitioner would “giv[e] up the right to have

2 the appellate court consider most claims of error and whether the sentence . . . is excessive and should be modified.” (Id. at 13.) Petitioner again affirmed he had consulted with his lawyer and understood. (Id.) The trial court then explained the conditions of Petitioner’s plea agreement: First, you must appear for your meeting with the probation department concerning your Presentence Investigation Report. You must cooperate with the probation department, which includes being truthful with them about the facts and circumstances of your cases. You must stay out of trouble and not get re-arrested on any other matter or commit any crimes while you are out pending sentence. . . . You must also come to court on the date of your sentence or any other date that [the judge] schedule[s] on your case.

(Id. at 19.) The trial court then asked Petitioner if he understood that failure to follow any condition would release the trial court from its sentencing promise, and Petitioner would not be allowed to withdraw his guilty plea and appellate waiver. (Id. at 19–20.) Petitioner responded “[y]es.” (Id.) Petitioner failed to appear for his sentencing on October 30, 2020, and a bench warrant was issued for his arrest. (Mem. of Law in Opp’n, Ex. 13-1, at 82 (Dkt. No. 13).) On December 23, 2020, Petitioner was arrested and remanded to the custody of the State pending sentencing and updates to his Presentence Investigation Report. (Aff. of Andrew Kass in Opp’n ¶ 6 (Dkt. No. 12).) In February 2021, the State notified the trial court that Petitioner was arrested in violation of the conditions of the plea agreement while awaiting sentencing. (Mem. of Law in Opp’n, Ex. 13-2, at 48 (Dkt. No. 13).) Subsequently, the State informed the trial court that it would seek consecutive, not concurrent, sentences. (Id. at 50.) At the sentencing hearing on July 29, 2021, the trial court noted Petitioner’s prior failure to appear at his sentencing hearing or his second Pre-Sentence Investigation interview, and his arrests while awaiting sentencing. (Mem. of Law in Opp’n, Ex. 13-4, at 4–6 (Dkt. No. 13).) The trial court held a hearing to assess whether there was a sufficient evidentiary basis for Petitioner’s arrest that the court could 3 conclude he violated his plea agreement and impose an enhanced sentence. (Id. at 4–6.). In the hearing, the State proffered evidence that Petitioner’s arrests stemmed from numerous “criminal and traffic offenses.” (Id. at 7.) A probation officer testified that she “attempted to conduct a presentence investigation interview in the jail with the defendant” but that he “refused to . . . cooperate with the interview” and did not return the probation office’s questionnaire. (Id. at 9.)

Petitioner claimed he “[did not] recall” receiving a phone call or a letter from the probation department for an interview. (Id. at 18.) Further, Petitioner argued there was no basis to prove the conduct underlying his Bergen County arrest. (Id. at 12-13.) Petitioner explained he was absent from the first sentencing hearing because his mother died that day, a fact which he claimed he relayed to his probation officer. (Id. at 15.) As to his failure to appear after he was notified of the bench warrant, Petitioner blamed the COVID-19 pandemic and his belief that the court threatened him “with 108 years” of imprisonment. (Id. at 16.) The trial court responded that the State advised Petitioner previously of the sentence it would seek if he was convicted and sentenced on each count, which was less than 108 years. (Id.

at 17.) Petitioner also informed the trial court that while awaiting sentencing he “ran by [his counsel] . . . to withdraw [his guilty] plea,” and wanted “to continue litigating [his] case.” (Id. at 17.) The trial court responded that “when [Petitioner] plead[ed] guilty the litigation [was] over” and that he was “fully allocated on the record,” then continued discussing Petitioner’s sentencing. (Id. at 17–18.) After hearing evidence, the trial court found a “reasonable basis to believe” Petitioner had been arrested on at least two occasions while awaiting sentencing, and that he failed to cooperate with the probation department. (Id.

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