Service v. Noeth

CourtDistrict Court, S.D. New York
DecidedDecember 4, 2024
Docket1:17-cv-04941
StatusUnknown

This text of Service v. Noeth (Service v. Noeth) 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
Service v. Noeth, (S.D.N.Y. 2024).

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: monn nnn nnn nnn aren nnn mannan KK DATE FILED:_12/04/2024 MICHAEL K. SERVICE, : Petitioner, : : 17-cv-4941 (LJL) -against- : : MEMORANDUM AND JOSEPH NOETH, : ORDER Respondent. :

wn ee KX LEWIS J. LIMAN, United States District Judge: Petitioner Michael Service (“Petitioner”) filed this petition for writ of habeas corpus (the “Tnitial Petition”) on June 29, 2017, and filed an amended petition on July 19, 2022 (the “Amended Petition” and collectively with the Initial Petition, the “Petition”). By Report and Recommendation dated October 6, 2023, Magistrate Judge Sarah Netburn recommended that the Petition be denied. Dkt. No. 55. On November 17, 2023, Petitioner filed written objections to the Report and Recommendation. Dkt. No. 58. Respondent replied by letter dated December 1, 2023. Dkt. No. 59. The Court has conducted a de novo review. For the following reasons, the Court adopts Judge Netburn’s recommendation that the Petition be denied and that a certificate of appealability not be issued. BACKGROUND The Court refers to the Report and Recommendation for a comprehensive description of the facts and procedural history of the case. Dkt. No. 55 at 1-10. A. The State Court Proceedings Petitioner was convicted on January 13, 2011, by a jury in New York Supreme Court, New York County, on charges of second-degree murder in violation of N.Y. Penal Law §

125.25(1), assault in the first degree in violation of N.Y. Penal Law § 120.10(1), and two counts of second-degree criminal possession of a weapon in violation of N.Y. Penal Law § 265.03(1)(b). Dkt. No. 55 at 8. The trial evidence is summarized ably in Judge Netburn’s Report and Recommendation. Id. at 5–8. Petitioner was sentenced to an aggregate term of

imprisonment of 45 years to life. Dkt. No. 50 at 1. Petitioner appealed to the Appellate Division, First Department. He sought relief on five grounds: (1) the trial court’s improper admission of his pretrial confessions; (2) the trial court’s failure to grant his motion to substitute counsel; (3) trial counsel’s failure to move for an order of dismissal on the assault count and assertion of a justification defense; (4) the legal sufficiency of the evidence supporting his assault conviction; and (5) the court’s unlawful imposition of consecutive sentences for murder and weapon possession. Dkt. No. 55 at 8. On March 31, 2015, the Appellate Division affirmed Petitioner’s conviction but, consistent with the State’s concession, agreed that the sentences for murder and weapon possession should run concurrently and not consecutively. See People v. Service, 6 N.Y.S.3d 246 (1st Dep’t 2015).

Petitioner sought leave to appeal from the New York Court of Appeals on the same grounds. Dkt. No. 15 at 25; Dkt. No. 55 at 9. On April 5, 2016, the Court of Appeals denied Petitioner’s application for leave to appeal. See People v. Service, 59 N.E.3d 1227 (N.Y. 2016). B. Petitioner’s Habeas Corpus Petition Petitioner filed his Initial Petition on June 24, 2017, proceeding pro se. Dkt. No. 1. In his Initial Petition, Petitioner sought relief on four grounds: (1) that the trial court improperly admitted his pretrial confessions; (2) that the trial court erred in denying his motion to substitute counsel; (3) that trial counsel was ineffective for failing to move for a trial order of dismissal on the assault count and for asserting a justification defense; and (4) that there was insufficient evidence to support a finding of serious physical injury. Id. at 6. Respondent filed an answer to the Initial Petition on November 17, 2017. Dkt. No. 14. On January 29, 2018, Petitioner moved the Court for a stay pending resolution of a petition for coram nobis he filed in state court. Dkt. No. 20. The coram nobis petition alleged

that Petitioner’s appellate counsel was ineffective for failing to argue that trial counsel had a conflict of interest and that the trial court abused its discretion by failing to conduct a sufficient inquiry into the conflict of interest and instead forcing Petitioner to proceed to trial with an attorney he did not trust. Id. On February 5, 2018, Magistrate Judge Netburn, to whom the case was referred, Dkt. No. 4, granted Petitioner’s motion to stay his Petition pending the state court’s resolution of the petition for coram nobis, Dkt. No. 21. On July 23, 2020, Judge Netburn lifted the stay after the parties informed the Court that the New York Court of Appeals had denied Petitioner’s request for leave to appeal the denial of his coram nobis petition. Dkt. No. 35. Judge Netburn gave Petitioner leave to amend the Initial Petition to include the claims raised in his coram nobis petition. Id.

On September 16 and 18, 2020, counsel appeared on behalf of Petitioner, Dkt. Nos. 36, 39, and on December 3, 2020, counsel filed a motion to stay adjudication of the Petition in order for Petitioner to exhaust in state court the claims that counsel stated were potentially meritorious, Dkt. No. 44. Judge Netburn granted the motion on February 8, 2021. Dkt. No. 47. Judge Netburn also gave Petitioner leave to amend the Petition to include additional claims if the claims were rejected by the state court and gave Respondent the opportunity to argue that the amended claims did not relate back and were therefore untimely. Id. Petitioner filed his Amended Petition on July 19, 2022. Dkt. No. 50. In addition to the four grounds alleged in the Initial Petition, Petitioner added arguments that appellate counsel was ineffective for four reasons. Dkt. No. 55. Specifically, appellate counsel failed to argue (5) that Petitioner’s statements should have been suppressed as the fruit of an unlawful arrest; (6) that the trial court unduly interfered with Petitioner’s testimony; (7) that Petitioner’s trial attorney was ineffective for disavowing parts of his testimony; and (8) that the trial court committed reversible

error under People v. O’Rama, 579 N.E.2d 189 (1991). Dkt. No. 55. C. Judge Netburn’s Report and Recommendation Judge Netburn recommended that the Petition be denied in its entirety. Dkt. No. 55 at 27. Judge Netburn rejected the claim in the Initial Petition that the trial court erred in its admission of his confessions and the claim in the Amended Petition that appellate counsel was ineffective for failing to argue that his confession was the fruit of an unlawful arrest. Id. at 17– 21. Construing liberally the confession allegations in the Initial Petition to raise both Fourth and Fifth Amendment claims, Judge Netburn concluded that the Fourth Amendment claim was barred by Stone v. Powell, 428 U.S. 465 (1976), because New York courts provided Petitioner with the appropriate corrective procedures to address an alleged Fourth Amendment violation

and Petitioner had not shown an “unconscionable breakdown in the underlying process,” Dkt. No. 55 at 18–19 (quoting Capellan v. Riley, 975 F.2d 67, 70 (2d Cir. 1992)). Judge Netburn also concluded that Petitioner failed to make out that his confession was involuntary under the Fifth Amendment. Id. at 20–21.

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Bluebook (online)
Service v. Noeth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/service-v-noeth-nysd-2024.