Cardello-Smith v. Director, Metropolitan Detention Center, Brooklyn New York
- Laura Swain
- 1:25-cv-03498
- U.S. District Court · Southern District of New York
- 3
In Cardello-Smith v. Director, Judge Swain denied Cardello-Smith’s habeas petition for lacking authority to represent Sean Combs as a “next friend.”
Derrick Lee Cardello-Smith’s attempt to bring a Section 2241 habeas petition on behalf of Sean John Combs was rejected because he did not establish that he could act as Combs’s representative. The order also affected Cardello-Smith’s ability to appeal without paying filing fees.
What happened
In Cardello-Smith v. Director, Derrick Lee Cardello-Smith filed a habeas petition under Section 2241 on behalf of Sean Combs. The opinion states that Cardello-Smith was incarcerated in Michigan, paid the filing fee, and represented himself.
The court said a person filing for someone else must show why that person cannot file personally and must show a significant relationship with, and dedication to the interests of, that person. Cardello-Smith did not explain why Combs needed a representative, show a significant relationship, or allege that Combs was unable to proceed on his own.
The court denied the petition without prejudice because Cardello-Smith lacked standing to bring it for Combs. Judge Swain also denied a certificate of appealability and denied permission to appeal without paying filing fees, finding that an appeal would not be taken in good faith.
The detailed version
- Cardello-Smith v. Director, Metropolitan Detention Center, Brooklyn New York · No. 1:25-cv-03498
- Laura Swain
- July 15, 2025
Background
Derrick Lee Cardello-Smith filed a petition under 28 U.S.C. § 2241 seeking habeas corpus relief on behalf of Sean John Combs, also known as Puff Daddy and Brother Love. Habeas corpus is a procedure for challenging unlawful custody. The petition named the Director of the Metropolitan Detention Center in Brooklyn, New York, and another person described in the caption as having custody. The opinion states that Cardello-Smith was incarcerated at Ionia Bellamy Creek Correctional Facility in Michigan, paid the filing fee, and proceeded without a lawyer.
Legal standard
The court explained that a habeas petition may be filed by the person seeking relief or by someone acting on that person’s behalf. A representative seeking to act as a “next friend” must show why the person seeking relief cannot appear personally, such as because of inaccessibility, mental incompetence, or another disability. The representative must also show dedication to that person’s best interests and, as suggested by the court, a significant relationship with that person. The representative bears the burden of establishing the right to proceed in that role.
Court’s analysis
The court found that Cardello-Smith did not explain why using the “next friend” procedure was necessary. He did not show that he had a significant relationship with Combs or that he was truly dedicated to Combs’s best interests. He also did not allege facts showing that Combs was disabled, incompetent, or otherwise unable to proceed on his own behalf. The court therefore concluded that Cardello-Smith lacked standing to bring a Section 2241 petition for Combs.
Ruling and additional orders
The court denied the habeas petition without prejudice. The conclusion states that the petition was denied. The court directed the Clerk of Court to mail Cardello-Smith a copy of the order and note service on the docket. It also ruled that no certificate of appealability would issue because the petition did not make a substantial showing that a constitutional right had been denied. Finally, under 28 U.S.C. § 1915(a)(3), the court denied permission to appeal without paying the filing fees, finding that any appeal would not be taken in good faith. The court did not reach the merits of any detention claim concerning Combs.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.