Griffin v. Superintendent of the Manhattan Detention Complex
- Colleen McMahon
- 1:20-cv-01833
- U.S. District Court · Southern District of New York
- 2
In Griffin v. Superintendent, Judge McMahon denied Griffin’s duplicate pretrial-detention habeas petition without prejudice because a similar petition was already pending.
Jeremiah J. Griffin, whose duplicate petition was denied without prejudice while his substantially similar petition remained pending in another case.
What happened
Griffin v. Superintendent of the Manhattan Detention Complex concerns Jeremiah J. Griffin’s self-represented petition challenging the constitutionality of his pretrial detention.
The court found that Griffin had already filed a substantially similar petition, which was pending before Judge Alison Nathan in another case. Because this petition raised the same claims, the court said there was no useful purpose in litigating it separately and denied it without prejudice to the pending application.
Chief Judge Colleen McMahon also declined to issue a certificate allowing an appeal and denied permission to proceed without paying filing fees for any appeal, finding that an appeal would not be taken in good faith.
The detailed version
- Griffin v. Superintendent of the Manhattan Detention Complex · No. 1:20-cv-01833
- Colleen McMahon
- Mar. 3, 2020
Background
Jeremiah J. Griffin, who was incarcerated at Rikers Island, filed the petition without a lawyer under 28 U.S.C. § 2241. A petition under that statute asks a federal court to review the legality of a person’s detention. Griffin challenged the constitutionality of his pretrial detention.
Reasoning
The court stated that Griffin had previously filed a substantially similar petition challenging the same pretrial detention. That earlier petition was pending before Judge Alison Nathan in case number 20-CV-1707 (AJN). Because the new petition raised the same claims, the court concluded that separately litigating it would serve no useful purpose.
Ruling
The court denied the petition without prejudice to Griffin’s pending application in case number 20-CV-1707 (AJN). The court 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. In addition, the court certified that an appeal would not be taken in good faith and denied permission to proceed without paying filing fees for purposes of an appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.