Santos Carrero Silva v. William Keyser

CourtDistrict Court, S.D. New York
DecidedNovember 20, 2025
Docket1:16-cv-07609
StatusUnknown

This text of Santos Carrero Silva v. William Keyser (Santos Carrero Silva v. William Keyser) 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.

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Santos Carrero Silva v. William Keyser, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ──────────────────────────────────── SANTOS CARRERO SILVA, 16-cv-7609 (JGK) Petitioner, MEMORANDUM OPINION - against - AND ORDER

WILLIAM KEYSER,

Respondent. ──────────────────────────────────── JOHN G. KOELTL, District Judge: In 2013, after a jury trial in the New York State Supreme Court, Bronx County, the petitioner, Santo Carrero Silva, was convicted of murder in the second degree and criminal possession of a weapon in the second degree. Silva directly appealed to the Appellate Division, which affirmed his conviction. People v. Silva, 22 N.Y.S.3d 834 (App. Div. 2016). Silva then sought leave to appeal from the New York Court of Appeals, but the applica- tion was denied. People v. Silva, 28 N.Y.3d 936 (2016). Next, Silva sought collateral review of his conviction from this Court pursuant to 28 U.S.C. § 2254, arguing, among other things, that the prosecution presented improper argument during its closing summation. This Court denied his petition for a writ of habeas corpus on the grounds that (1) Silva had failed to exhaust his state court remedies; (2) the Appellate Division’s ruling rested on an adequate and independent state ground; and (3) Silva’s due-process claim lacked merit. Silva v. Keyser, 271 F. Supp. 3d 527 (S.D.N.Y. 2017). Silva, who is pro se, now moves pursuant to Federal Rule of Civil Procedure 60(b) to vacate this Court’s earlier denial of his petition for a writ of habeas corpus.

I. A. In April 2010, a Bronx County grand jury returned an in- dictment charging Silva with one count each of murder in the second degree, manslaughter in the first degree, and possession of ammunition; and two counts of criminal possession of a weapon in the second degree. Id. at 535–36. During its summation at trial, the prosecution argued that Silva killed the decedent in part because Silva was frustrated with his own living conditions. Id. at 536. Specifically, the prosecution argued that Silva was motivated to kill because he lived in a “hovel,” and, to that end, the prosecution introduced

photographic evidence during the trial of the petitioner’s liv- ing conditions. Id. The jury ultimately found Silva guilty of one count of sec- ond-degree murder and one count of second-degree criminal possession of a weapon. Id. The court sentenced Silva to a term of imprisonment of twenty years to life for the second-degree murder conviction and five years for the weapons charge, to run concurrently. Id. Silva appealed his conviction to the Appellate Division, First Department, arguing, among other things, that the prosecu- tion engaged in various forms of misconduct during summation,

including by arguing a motive theory that had no evidentiary ba- sis. Id. The Appellate Division affirmed Silva’s conviction, rejecting his “challenges to the prosecutor’s summation” as un- preserved and holding in the alternative that “any improprieties in the summation did not rise to the level of reversible error.” Silva, 22 N.Y.S.3d at 834. Silva applied for leave to appeal from the New York Court of Appeals, but his application was de- nied. Silva, 28 N.Y.3d at 936. B. Following his direct appeal, Silva petitioned this Court for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. Silva raised in his petition the same claims he brought in his direct

appeal. This Court denied Silva’s petition and rejected his challenge to the prosecution’s summation on three grounds. First, Silva’s argument was unexhausted because he had not presented it to the Appellate Division in federal constitutional terms, nor did he raise the argument in his application for leave to appeal to the Court of Appeals. Silva, 271 F. Supp. 3d at 542, 545. Second, Silva’s challenge was procedurally barred by an ad- equate and independent state-law ground. Specifically, he had failed to object contemporaneously during the prosecution’s sum- mation, and the Appellate Division therefore rejected his argument as unpreserved. Id. at 543 (noting that “New York’s

contemporaneous objection rule, on which the Appellate Division relied, is a firmly established, independent, and adequate state ground that bars habeas review of the merits of a constitutional claim”). Third, Silva’s challenge to the summation was without merit because “it [wa]s clear that the petitioner ‘would have been convicted even without’ the challenged remarks.” Id. at 544 (quoting United States v. Elias, 285 F.3d 183, 192 (2d Cir. 2002)). Silva moved for a certificate of appealability from the Court of Appeals for the Second Circuit, which denied his motion and dismissed his appeal. Silva v. Keyser, No. 17-cv-3324, 2018 WL 1831778, at *1 (2d Cir. Mar. 26, 2018).

Silva now moves pursuant to Rule 60(b) to vacate this Court’s earlier denial of his habeas petition. II. Federal Rule of Civil Procedure 60(b) provides “for relief from a final judgment, order, or proceeding.” Davis v. New York, No. 07-cv-9265, 2017 WL 5157458, at *2 (S.D.N.Y. Nov. 6, 2017). Subdivision (b)(6) is a “catchall category,” which “permits a court to reopen a judgment for any other reason that justifies relief.” Buck v. Davis, 580 U.S. 100, 123 (2017). “Relief is available under subdivision (b)(6), however, only in extraordi- nary circumstances.” Id. at 112. Rule 60(b) applies in habeas corpus cases and may be used

to reopen a habeas proceeding. Gonzalez v. Crosby, 545 U.S. 524, 534 (2005) (“Rule 60(b) has an unquestionably valid role to play in habeas cases.”). However, “a Rule 60(b) motion has a differ- ent objective than a habeas petition.” Carbone v. Cunningham, 857 F. Supp. 2d 486, 488 (S.D.N.Y. 2012). A Rule 60(b) motion challenges “the integrity of the federal habeas proceedings.” Gonzalez, 545 U.S. at 532. Typical grounds for a Rule 60(b) mo- tion attacking a district court’s denial of a habeas petition include that the “court erroneously avoided deciding the merits of a claim for reasons such as failure to exhaust, procedural default, or statute-of-limitations bar.” Robles v. Lempke, No. 09-cv-2636, 2018 WL 1320657, at *4 (E.D.N.Y. Mar. 14, 2018).

By contrast, “a motion that attacks the underlying conviction” is properly characterized as a second or successive habeas peti- tion. Harris v. United States, 367 F.3d 74, 82 (2d Cir. 2004). For example, a motion that “contend[s] that a subsequent change in substantive law is a reason justifying relief” under Rule 60(b)(6) “is in substance a successive habeas petition and should be treated accordingly.” Gonzalez, 545 U.S. at 531. This distinction is crucial because “[u]nder the Antiter- rorism and Effective Death Penalty Act (‘AEDPA’), successive federal habeas petitions requesting relief from a conviction in state court must satisfy strict requirements before a district court can adjudicate them on the merits.” Hamilton v. Lee, 188

F. Supp. 3d 221, 239 (E.D.N.Y. 2016) (citing 28 U.S.C.

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