Sandoval-Campos v. Security
- Laura Swain
- 1:25-cv-07993
- U.S. District Court · Southern District of New York
- 2
In Sandoval-Campos v. Homeland Security, Judge Swain closed this case and directed its petition be docketed in an earlier related case.
Ronal Danilo Sandoval-Campos’s petition was moved onto the docket of the earlier related proceeding, No. 24-CV-3854, and the new action, No. 25-CV-7993, was closed.
What happened
Ronal Danilo Sandoval-Campos filed a petition asking for relief from custody under a federal law that allows challenges to state-court convictions or detention. The court said the petition arose from the same events as an earlier related case and had been opened as a new case by mistake.
The court directed the Clerk of Court to docket the petition as a second amended petition in the earlier related case, No. 24-CV-3854. It also directed the Clerk to close this action, No. 25-CV-7993. The opinion did not decide the substance of Sandoval-Campos’s claims.
Judge Laura Taylor Swain also ruled that no certificate permitting an appeal would issue because the petition did not make a substantial showing that a constitutional right had been denied. She further denied permission to appeal without paying filing fees, stating that an appeal would not be taken in good faith.
The detailed version
- Sandoval-Campos v. Security · No. 1:25-cv-07993
- Laura Swain
- Oct. 2, 2025
Background
On September 26, 2025, the court received Ronal Danilo Sandoval-Campos’s self-represented petition for a writ of habeas corpus under 28 U.S.C. § 2254. A habeas petition seeks court-ordered relief from allegedly unlawful custody. The petition was opened as a new civil action under No. 25-CV-7993.
The court stated that Sandoval-Campos had previously filed a § 2254 petition arising from the same events in an earlier related proceeding, No. 24-CV-3854. In that proceeding, the court had allowed him to file a second amended petition.
Court’s Action
After reviewing the petition, the court determined that this action had been opened in error. It concluded that the petition should have been docketed as a second amended petition in the earlier related proceeding rather than as a new civil action.
The court therefore directed the Clerk of Court to docket the petition filed in this action as a second amended petition in No. 24-CV-3854. It further directed the Clerk to close No. 25-CV-7993. The court did not reach the merits of the petition’s constitutional or other claims.
Appeal-Related Rulings
The court stated that the petition did not make a substantial showing that a constitutional right had been denied, so it ruled that a certificate of appealability would not issue. A certificate of appealability is required for an appeal from certain habeas decisions.
The court also certified that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees under 28 U.S.C. § 1915(a)(3).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.