White v. Noeth

CourtDistrict Court, S.D. New York
DecidedMay 1, 2025
Docket7:19-cv-00097
StatusUnknown

This text of White v. Noeth (White 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
White v. Noeth, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

EQUARN WHITE,

19-cv-97 (KMK) (AEK) Petitioner,

REPORT AND - against - RECOMMENDATION

JOSEPH NOETH,

Respondent. TO: THE HONORABLE KENNETH M. KARAS, U.S.D.J. On January 4, 2019, the petition for a writ of habeas corpus filed by pro se Petitioner Equarn White, which originally was filed in the United States District Court for the Eastern District of New York, and initially was transferred to the United States District Court for the Western District of New York, was transferred to this Court. ECF No. 5; see ECF No. 1 (“Petition” or “Pet.”). In the Petition, Petitioner challenges a December 9, 2015 decision arising out of a disciplinary proceeding at Green Haven Correctional Facility,1 in which he was sentenced to one year in the special housing unit and loss of privileges (subsequently modified to 270 days), and loss of one year of good time credit; according to Petitioner, the sentence resulted in his not being released on August 18, 2018, which he alleges was his conditional release date. See Pet. at 17, 22; see also ECF No. 13-2 (State Court Record) at SR 349-51 (decision denying

1 When the Petition was filed on October 22, 2018, Petitioner was incarcerated at Attica Correctional Facility. See Pet. at 1. In a note dated August 8, 2019, Petitioner informed the Court that he had been transferred to Clinton Correctional Facility. ECF No. 20. Then, in a note dated October 11, 2019, Petitioner informed the Court that he had been transferred to Fishkill Correctional Facility. ECF No. 21. Petitioner was thereafter released from custody, and he sent notes to the Court on November 25, 2019, and April 12, 2020, providing the Court with updated addresses in Brooklyn, New York. ECF Nos. 22, 23. The Court has not received any further updates to Petitioner’s contact information. Article 78 petition). Petitioner claims that the disciplinary hearing officer denied him due process both before and during his hearing, see Pet. at 11-17, and that the punishment imposed after the hearing likewise violated his right to due process, see id. at 22-23. Petitioner also claims that his rights to due process and equal protection were violated when the Appellate Division, Second Department denied his motion for poor person relief when he sought to appeal

the denial of the Article 78 petition he had filed contesting the disciplinary hearing decision. See id. at 5, 23. On April 22, 2019, Respondent filed his opposition to the Petition. ECF Nos. 13-15. Petitioner’s reply was docketed on May 17, 2019. ECF No. 16. According to Petitioner’s profile in the Department of Corrections and Community Supervision (“DOCCS”) “incarcerated lookup” database, Petitioner was granted conditional release to parole on November 25, 2019; the maximum expiration date of his sentence of incarceration was August 18, 2020, and the maximum expiration date for his post-release supervision was March 14, 2023. See Exhibit A.2 Consequently, as explained below, the

Petition is now moot. Therefore, I respectfully recommend that the Petition be dismissed with prejudice. DISCUSSION I. Legal Standard for Mootness The Court has no jurisdiction over any matter that does not present an actual, ongoing case or controversy pursuant to Article III, Section 2 of the United States Constitution. See, e.g., Untied States v. Vargas, 63 F. App’x 592, 595 (2d Cir. 2003) (summary order) (“Article III,

2 Petitioner’s profile can no longer be found in the database. The document attached as Exhibit A to this Report and Recommendation is a true and correct copy of a print-out from the database that was generated by Court personnel on January 10, 2024. Section 2 of the United States Constitution limits federal subject matter jurisdiction to those cases that present a ‘case or controversy.’”)3; Williams v. Monroe Cnty. Jail Superintendent, 730 F. Supp. 3d 30, 34 (W.D.N.Y. 2024). The constitutional requirement that there be an ongoing “case or controversy” means that “throughout the litigation, the plaintiff must have suffered, or be threatened with, an actual injury traceable to the defendant and likely to be redressed by a

favorable judicial decision.” Spencer v. Kemna, 523 U.S. 1, 7 (1998) (quotation marks omitted). “If the issues presented by the case are no longer live or the parties lack a legally cognizable interest in the outcome, the case is moot, thereby depriving the court of jurisdiction to hear it.” Williams, 730 F. Supp. 3d at 34 (cleaned up) (citing Blackwelder v. Safnauer, 866 F.2d 548, 550 (2d Cir. 1989)). “[M]ootness is not fixed at the time of filing but must be considered at every stage of the habeas proceeding.” Nowakowski v. New York, 835 F.3d 210, 217 (2d Cir. 2016). “Once, as here, a petitioner’s sentence has expired, ‘some concrete and continuing injury other than the now-ended incarceration or parole—some ‘collateral consequence’ of the conviction— must exist if the suit is to be maintained.’” Id. at 217-18 (quoting Spencer, 523 U.S. at 7).

“When a petitioner challenges his [or her] criminal conviction, the Supreme Court has been willing to presume the existence of collateral consequences sufficient to satisfy the case or controversy requirement.” McCray v. Anderson, No. 20-cv-2247 (VB), 2024 WL 4277673, at *3 (S.D.N.Y. Sept. 24, 2024) (quotation marks omitted). “However, where a habeas petitioner only challenges a sentencing enhancement, and not the underlying conviction itself, the court does not presume the existence of collateral consequences because comparable civil disabilities generally

3 In accordance with Lebron v. Sanders, 557 F.3d 76 (2d Cir. 2009), and Local Civil Rule 7.2 of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, copies of this case and other cases that are unpublished or only available by electronic database are being simultaneously mailed to the pro se Petitioner along with this Report and Recommendation. do not arise from the length of a sentence.” Id. (quotation marks omitted). In the habeas context, if a petitioner’s sentence ends before final adjudication of the habeas petition, any challenges to the validity of the sentence are mooted. See Lane v. Williams, 455 U.S. 624, 631-33 (1982); North Carolina v. Rice, 404 U.S. 244, 248 (1971) (per curiam) (“Nullification of a conviction may have important benefits for a defendant, . . . but urging in a habeas corpus proceeding the

correction of a sentence already served is another matter.”); see also McCray, 2024 WL 4277673, at *3 (“This court has repeatedly held that challenges to the validity of a sentence are mooted by the expiration of that sentence and thus not justiciable once the sentence has been served.”) (quotation marks omitted). II. Analysis Because the maximum expiration dates for both Petitioner’s sentence of incarceration and his post-release supervision have expired, the Court must assess whether the Petition still presents a justiciable case or controversy. Here, Petitioner’s habeas claims are focused primarily on how his 2015 disciplinary hearing was conducted and the Appellate Division, Second

Department’s denial of his motion for poor person relief on appeal of the denial of his Article 78 petition. Petitioner does not challenge either his underlying criminal conviction or his post- release supervision.

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