Sanchez v. Warden
- Laura Swain
- 1:24-cv-01251
- U.S. District Court · Southern District of New York
- 3
In Sanchez v. Warden, Judge Swain dismissed Willy Sanchez’s petition without prejudice after he failed to follow the court’s filing instructions.
Willy Sanchez’s petition was dismissed without prejudice. The court also denied him permission to proceed without prepaying fees for an appeal.
What happened
In Sanchez v. Warden, Willy Sanchez sought relief under the First Step Act, including a sentence reduction based on changes called Amendments 821 and 817. The court treated his filing as a petition under a federal law allowing certain challenges to detention.
The court instructed Sanchez to pay a $5 filing fee or submit an application to proceed without paying it upfront, and to complete and sign the required petition form. Sanchez instead filed a motion asking the court to explain more specifically which First Step Act grounds applied to him. The court provided general information but did not determine whether he qualified for relief.
Because Sanchez did not comply with the court’s May 1, 2024 order, Judge Laura Taylor Swain dismissed the petition without prejudice. The court also denied permission to proceed without paying court fees on appeal and directed the Clerk to enter judgment.
The detailed version
- Sanchez v. Warden · No. 1:24-cv-01251
- Laura Swain
- July 1, 2024
Background
Willy Sanchez submitted a letter seeking relief related to his federal conviction. He referred to Amendment 821 and to the First Step Act’s safety-valve provision, which involves a sentencing rule. He also asked the court to assign the public defender’s office to review his matter and provide legal assistance.
In an earlier order in the related criminal proceeding, Judge Kimba M. Wood treated Sanchez’s letter as a request to reduce his sentence under 18 U.S.C. § 3582(c)(2). Judge Wood found Sanchez ineligible for a sentence reduction under that provision, denied his request for counsel, and directed that the portion seeking First Step Act relief be opened as a new civil action under 28 U.S.C. § 2241. The Clerk opened this case as directed.
Procedural History
The court ordered Sanchez to pay the $5 filing fee or submit an application to proceed without prepaying the fee. It also required him to complete and sign a petition under 28 U.S.C. § 2241, the federal statute used for certain challenges to detention or custody.
Sanchez responded with a motion for a “complete definite statement.” He asked the court to identify the applicable First Step Act grounds for relief. The court explained who may be eligible for relief under the First Step Act but made no decision about Sanchez’s eligibility. It also explained that the court could not advise him about which grounds to assert in a petition. The court again directed him to pay the fee or submit an application to proceed without prepayment and to complete and sign the required petition form within 30 days.
Ruling
The court stated that Sanchez did not comply with its May 1, 2024 order. It therefore dismissed the petition without prejudice under 28 U.S.C. §§ 1914 and 1915. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The Clerk was directed to enter judgment.
Classification
This is a procedural order because the court dismissed the petition for failure to follow filing instructions and did not decide whether Sanchez qualified for First Step Act relief.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.