Nelson Donigan v. Daniel F. Martuscello III, Commissioner of the New York State Department of Corrections and Community Supervision

District Court, E.D. New York·Decided September 2, 2026·No. 1:23-cv-01740·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

NELSON DONIGAN,

Petitioner, v. MEMORANDUM & ORDER 23-CV-01740 (HG) DANIEL F. MARTUSCELLO III, Commissioner of the New York State Department of Corrections and Community Supervision,

Respondent.1

HECTOR GONZALEZ, United States District Judge: Petitioner Nelson Donigan, who is currently in the custody of the New York State Department of Corrections and Community Supervision (“DOCCS”), petitions the Court for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. ECF No. 1 (Petition).2 Petitioner was convicted of two counts of criminal possession of a weapon in the second degree, one count of criminal possession of a weapon in the third degree, and one count of criminal possession of marijuana in the second degree following a bench trial in Queens County Supreme Court. ECF No. 7-1 at 275 (Trial Transcript). On August 28, 2018, Petitioner was sentenced as a persistent violent felony offender to an aggregate prison term of eighteen years to life. Id. at 6, 15–17

1 The Court substitutes Daniel F. Martuscello III, the current Commissioner of the New York State Department of Corrections and Community Supervision (“DOCCS”), in the case caption for Anthony J. Annucci, former Acting Commissioner of DOCCS. See Fed. R. Civ. P. 25(d). The Clerk of Court is respectfully directed to amend the caption accordingly.

2 Unless otherwise indicated, when quoting cases and the parties’ papers, the Court omits all internal quotation marks, alteration marks, emphases, footnotes, and citations. The Court refers to the pages assigned by the Electronic Case Files system (“ECF”), except when citing to the state court transcripts, where the Court refers to the original page numbers on the native documents. (Sentencing Transcript). Petitioner appealed his conviction, but the New York Appellate Division, Second Department (“Appellate Division”) affirmed the judgment. ECF No. 1-2 at 1 (Ex. A; Decision & Order). Thereafter, the New York Court of Appeals denied Petitioner’s request for leave to appeal. ECF No. 1-6 at 11 (Ex. E; Order Denying Leave). Petitioner challenges the legal sufficiency of the evidence supporting his conviction and

asserts that the Appellate Division unreasonably applied clearly established Supreme Court precedent in In re Winship, 397 U.S. 358 (1970) and Jackson v. Virginia, 443 U.S. 307 (1979).3 ECF No. 1 at 23, 25. Respondent opposes the petition. ECF No. 8-1 (Memorandum of Law in Opposition to Petition). For the reasons set forth below, the petition is DENIED. BACKGROUND4 On December 1, 2016, New York Police Department (“NYPD”) officers executed a warrant to search Petitioner’s home in Queens, which he shared with four family members: his wife, mother, grandmother, and brother. ECF No. 7-1 at 72–74, 126–27, 215. Petitioner lived in a basement bedroom with his wife, which was separated from the rest of the house by an iron

door. Id. at 76–77, 81, 128, 215. The basement consisted of Petitioner’s bedroom and an adjacent storage room separated from the bedroom by a partial wall and a curtain, which was

3 Winship “established proof beyond a reasonable doubt as an essential of Fourteenth Amendment due process,” and Jackson held that “[a]fter Winship the critical inquiry on review of the sufficiency of the evidence to support a criminal conviction” is “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson, 443 U.S. at 317–19 (emphasis in original).

4 “Under 28 U.S.C. § 2254(e), the findings of fact which underlie the state court’s conclusion are entitled to the statutory presumption of correctness by the reviewing federal habeas court. Unless rebutted by clear and convincing evidence, the habeas court must accept the facts found by the state court as true.” Sanford v. Burge, 334 F. Supp. 2d 289, 301 (E.D.N.Y. 2004). open when Officer Connors, the officer conducting the search, entered the basement. Id. at 77, 129. The entrance to the storage area was roughly five feet from the foot of Petitioner’s bed. Id. at 83. Members of the NYPD Emergency Service Unit were the first to enter the basement, where one of the officers encountered and arrested Petitioner. Id. at 153–54. Subsequently,

Officer Connors entered the basement and immediately noticed a strong marijuana smell. Id. at 81. In the bedroom, Officer Connors found a wallet containing Petitioner’s driver’s license on a television stand and a photograph of Petitioner and his wife on top of the television. Id. at 86, 95–97, 104. Officer Connors also found a scale on the bedroom dresser, $11,939 in cash in the dresser, and a bulletproof vest in a crawl space behind Petitioner’s bed. Id. at 83, 86, 104. In the adjacent storage area, Officer Connors recovered approximately six pounds of marijuana in plastic bags and a .40 caliber firearm loaded with 12 rounds of ammunition that appeared shiny and new. Id. at 83–85, 91–92, 120. The marijuana was about three or four feet from the entrance to the storage area, and the firearm was about two to three additional feet from the

marijuana. Id. at 84–85. A forensic analysis could not determine whose DNA was on the firearm; it identified only the presence of male DNA and excluded Petitioner as a contributor. Id. at 201–203. Officer Connors had not seen Petitioner in the storage room, nor did he find any of Petitioner’s identifiable items in the storage room. Id. at 134, 139. Officer Connors also discovered six rounds of ammunition, matching the caliber of the gun, in an upstairs bedroom belonging to Petitioner’s brother. Id. at 87–88, 119–20. That ammunition appeared old, tarnished, and dirty. Id. at 92. Petitioner’s mother testified that another brother of Petitioner died shortly before the police search, and his belongings were brought to the home in bins and bags and stored in the basement and shed. Id. at 211–12. She had not gone through his belongings as of the date the warrant was executed and was not previously aware of the marijuana and firearm found in the storage room. Id. at 212, 217, 224. Based on the accessibility of the storage area from Petitioner’s bedroom, Petitioner’s presence in the basement during the execution of the search warrant, the readily accessible

weapon and distinct smell and large quantity of marijuana in the basement, and the recovery of the bulletproof vest and large amount of cash from Petitioner’s bedroom, the trial judge found that Petitioner “exercised sufficient dominion and control over the area in which the loaded and operable weapon and marijuana were found” such that he knowingly and “constructively possess[ed] [the] same” and had the requisite intent. Id. at 275–76. On March 20, 2018, the court rendered its guilty verdict following a bench trial in Queens County Supreme Court. Id. at 275. Petitioner was convicted of two counts of criminal possession of a weapon in the second degree, one count of criminal possession of a weapon in the third degree, and one count of criminal possession of marijuana in the second degree. Id. On August 28, 2018, Petitioner was sentenced as a persistent violent felony offender5 to the

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Nelson Donigan v. Daniel F. Martuscello III, Commissioner of the New York State Department of Corrections and Community Supervision, (E.D.N.Y. 2026).

Nelson Donigan v. Daniel F. Martuscello III, Commissioner of the New York State Department of Corrections and Community Supervision (Nelson Donigan v. Daniel F. Martuscello III, Commissioner of the New York State Department of Corrections and Community Supervision) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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