Daniel v. Superintendent
- Laura Swain
- 1:25-cv-05251
- U.S. District Court · Southern District of New York
- 22
In Eric Daniel v. Superintendent, Judge Stanton ordered Daniel to clarify and amend his state-prisoner habeas petition within 60 days.
Eric Daniel, the state prisoner seeking federal review, and the Superintendent named as respondent.
What happened
In Eric Daniel v. Superintendent, Eric Daniel challenged his October 3, 2023 New York state conviction in a petition filed under a federal law for challenging custody. The court treated the petition as one under the law governing challenges to state convictions, rather than the law Daniel cited. Daniel identified sentencing and mental-health grounds but did not provide enough facts or explain their constitutional basis.
The court also said Daniel had not stated whether he sought review by New York’s highest court after the Appellate Division affirmed his conviction on June 10, 2025. Before the case can proceed, he must explain his claims and describe the steps he took to complete review in the state courts.
Judge Louis L. Stanton granted Daniel 60 days to file an amended petition or notify the court that he wants to withdraw the case. The original petition remains designated under the state-conviction habeas law unless Daniel withdraws it; no response from the Superintendent was required at this stage. If Daniel does not comply and cannot show good cause, the petition will be denied without prejudice.
The detailed version
- Daniel v. Superintendent · No. 1:25-cv-05251
- Laura Swain
- Oct. 30, 2025
Background
Eric Daniel, who the opinion says is incarcerated at Clinton Correctional Facility, filed a petition challenging his October 3, 2023 conviction in New York Supreme Court, Bronx County. He filed the petition under 28 U.S.C. § 2241, but the court determined that the petition must be treated as a petition under 28 U.S.C. § 2254 because it challenges custody under a state-court judgment. The court had previously allowed Daniel to proceed without paying the filing fee.
Daniel identified two grounds for relief: that he was not sentenced under a New York guideline for a first felony conviction and that he has mental-health issues. The court found that he did not provide supporting facts or identify the constitutional basis for either ground. As a result, the court said neither it nor the respondent could understand the legal and factual basis of the claims well enough to adjudicate them.
State-court exhaustion
Before a federal court generally may decide a state prisoner’s § 2254 petition, the prisoner must give the state courts a full opportunity to review the federal constitutional claims. The court stated that Daniel alleged that the Appellate Division, First Department, affirmed his conviction on June 10, 2025, but he did not allege that he sought permission to appeal to the New York Court of Appeals or that permission was denied.
Court’s action
The court granted Daniel leave to file an amended § 2254 petition within 60 days of the order. Any amended petition must identify each ground for relief, provide supporting facts, and explain the steps taken to fully pursue those grounds in the New York courts. The court advised that an amended petition completely replaces the original petition.
The court also gave Daniel 60 days to notify it in writing if he does not want to pursue the case under § 2254. If he does not provide that notice, the original petition will remain designated as a § 2254 petition. If he does not comply with the order within the allowed time and cannot show good cause, the petition will be denied without prejudice. The court did not require the Superintendent to answer at this stage.
Classification
This is a procedural order, not a decision on whether Daniel’s conviction or sentence violated federal law. The court addressed the petition’s required form, its designation under § 2254, and the need to clarify and exhaust the claims, but did not decide the merits of Daniel’s allegations.
Read the full 22-page opinion on CourtListener, the free public archive maintained by the Free Law Project.