Squire v. Elmira Correctional Facility

CourtDistrict Court, E.D. New York
DecidedMay 12, 2025
Docket2:24-cv-07239
StatusUnknown

This text of Squire v. Elmira Correctional Facility (Squire v. Elmira Correctional Facility) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Squire v. Elmira Correctional Facility, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK For Online Publication Only -------------------------------------------------------------X KASHON SQUIRE, 23-B-0588,

Petitioner, MEMORANDUM & ORDER 24-CV-7239(JMA) -against-

ELMIRA CORRECTIONAL FACILITY,

Respondent. -------------------------------------------------------------X AZRACK, United States District Judge:

On October 2, 2024, petitioner Kashon Squire, appearing pro se, filed a Petition seeking writ of habeas corpus pursuant to 28 U.S.C. § 2254 (“Petition”) together with an application to proceed in forma pauperis (“IFP”). (See Petition, ECF No. 1, IFP Mot., ECF No. 2.) Upon review of Squire’s application to proceed IFP, the Court finds that he is qualified by his reported financial status to commence this action without prepayment of the filing fees. Accordingly, Squire’s application to proceed IFP is GRANTED. The Court has initially reviewed this Petition pursuant to Rule 4 of the Rules Governing Section 2254 Cases and, for the reasons that follow, has determined that the Petition names an improper respondent and, more importantly, is unexhausted. Accordingly, the Petition is sua sponte dismissed without prejudice as set forth below. BACKGROUND The Petition names Elmira Correctional Facility as the sole respondent and challenges Squire’s custody arising from his August 18, 2021 convictions in Suffolk County Court for assault in the second degree and resisting arrest. (See Pet. ¶¶ 1(a)-(b), 3, 5, 6(a)(1)-(b).) According to the Petition, Squire pled guilty to second degree assault and was sentenced to a term of incarceration of one-and-a-half to three years. (Id. at 1.) Squire previously filed a § 2254 petition that also challenged an August 18, 2021 conviction that resulted in a prison sentence of one-and-a-half to three years. That earlier petition was dismissed without prejudice because Squire had failed to exhaust his remedies his state court.2 For both of his petitions, Squire used a pro se form for § 2254 petitions that includes various check boxes and questions in order to assist pro se petitioners. DISCUSSION

I. Squire’s Pro Se Status Given his pro se status, the Court construes Squire’s submissions liberally and interprets them “to raise the strongest arguments that they suggest.” United States v. Pilcher, 950 F.3d 39, 44 (2d Cir. 2020) (per curiam) (quoting McLeod v. Jewish Guild for the Blind, 864 F.3d 154, 156 (2d Cir. 2017) (per curiam)). This policy is “driven by the understanding that implicit in the right to self-representation is an obligation on the part of the court to make reasonable allowances to protect pro se litigants from inadvertent forfeiture of important rights because of their lack of legal training.” McLeod, 864 F.3d at 156 (emphasis added; internal quotation marks omitted). This liberal interpretation of Squire’s submissions, however, “does not exempt [him] from compliance with relevant rules of procedural and substantive law.” See e.g., United States v. Starling, 76 F.4th

92, 99 (2d Cir. 2023) (quoting Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir. 1983)); see Faretta v.

1 The Petition does not indicate whether Squire pled guilty to resisting arrest or was convicted of this count at trial. It is unnecessary to determine the underlying basis for Squire’s resisting arrest conviction. In either event, Squire’s Petition would be dismissed without prejudice for failure to exhaust.

2 In a Memorandum and Order dated August 1, 2024, the Court granted Squire’s in forma pauperis application and dismissed his petition for failure to exhaust his remedies in state court. Squire v. Mickcorr Ramond New, 2:24-CV- 04174(JMA), ECF No. 8. Although this earlier Petition references an August 18, 2021 conviction for third degree assault, it appears that both of Squire’s petitions have sought to challenge the same assault conviction.

2 California, 422 U.S. 806, 834 n.46 (1975) (similar). II. Proper Respondent The Supreme Court instructs that “there is generally only one proper respondent to a given prisoner’s habeas petition . . . the person with the ability to produce the prisoner’s body before the habeas court.” Rumsfeld v. Padilla, 542 U.S. 426, 435 (2004) (emphasis added); see also Rules Governing § 2254 Cases, Rule 2(a) (Where, like here, “the petitioner is currently under a state- court judgment, the petition must name as respondent the state officer who has custody.”); Kendall v. INS, 261 F. Supp. 2d 296, 299 (S.D.N.Y. 2003) (“A writ of habeas corpus is an order upon the

person who holds [the prisoner] in what is alleged to be unlawful custody.”) (internal citations and quotations omitted). Here, Squire names only the Elmira Correctional Facility as the sole respondent. However, the only proper respondent is the warden of that facility. Accordingly, the petition is dismissed without prejudice and with leave to renew by naming the warden once his claims are properly exhausted as set forth below.3 III. Exhaustion “A federal court only has jurisdiction to hear a petition filed pursuant to title 28 U.S.C. section 2254 where the petitioner is ‘in custody pursuant to the judgment of a State court.’” Henry v. Davis, No. 10-CV-5172, 2011 WL 319935, at *1 (E.D.N.Y. Jan. 26, 2011) (quoting 28 U.S.C.

§ 2254(a) (“[A] district court shall entertain an application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States”)). Furthermore, a

3 Given Squire’s failure to exhaust the claims in the petition, (see infra at 3–6), the Court declines to sua sponte amend the caption to reflect the warden of the Elmira Correctional Facility as the respondent.

3 district court may not grant the writ “unless the petitioner has first exhausted the remedies available in the state court or shows that ‘there is an absence of available state corrective process; or circumstances exist that render such process ineffective to protect the rights of the applicant.’” Henry, 2011 WL 319935 at *1 (quoting 28 U.S.C. § 2254(b)(1)(B)(i)-(ii)); Aparicio v. Artuz, 269 F.3d 78, 90 (2d Cir. 2001). A federal claim is properly exhausted where it has been presented to the highest state court empowered to hear the claim. Henry, 2011 WL 319935 at *1 (citing Picard v. Connor, 404 U.S. 270, 275 (1971); Daye v. Attorney Gen. of New York, 696 F.2d 186, 190-91

(2d Cir. 1982)).

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Rumsfeld v. Padilla
542 U.S. 426 (Supreme Court, 2004)
Aparicio v. Artuz
269 F.3d 78 (Second Circuit, 2001)
Kendall v. Immigration & Naturalization Service
261 F. Supp. 2d 296 (S.D. New York, 2003)
McLeod v. the Jewish Guild for the Blind
864 F.3d 154 (Second Circuit, 2017)
United States v. Pilcher
950 F.3d 39 (Second Circuit, 2020)
United States v. Starling
76 F.4th 92 (Second Circuit, 2023)

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Squire v. Elmira Correctional Facility, Counsel Stack Legal Research, https://law.counselstack.com/opinion/squire-v-elmira-correctional-facility-nyed-2025.