Figueroa v. Keyser
- John Koeltl
- 1:20-cv-03013
- U.S. District Court · Southern District of New York
- 6
In Figueroa v. Keyser, Judge Koeltl declined to grant discovery because Figueroa had not completed state proceedings and showed no good cause.
William Figueroa's request for discovery in his federal petition; Respondent Keyser is the respondent named in the case.
What happened
In William Figueroa v. Keyser, Figueroa asked the federal court for records related to his prior criminal convictions, including certain police reports.
The court said Figueroa had not yet completed the available state-court proceedings related to his current federal petition. It also explained that any discovery request should first be directed to the state court.
The court did not grant the discovery request because Figueroa had not shown the required good cause for discovery in federal court. Judge John G. Koeltl issued the order on February 22, 2021.
The detailed version
- Figueroa v. Keyser · No. 1:20-cv-03013
- John Koeltl
- Feb. 22, 2021
Background
William Figueroa sent the court a letter concerning his federal petition related to prior criminal convictions. The court understood the letter as requesting discovery, meaning permission to obtain information or documents for use in the case. Figueroa specifically asked for production of what he described as still-missing police DD-5 reports numbered 176 and 197. His letter also discussed other reports, alleged disclosure violations, and claims concerning evidence related to his convictions.
Court's reasoning
The court stated that Figueroa had not yet exhausted his state-court remedies in connection with his current application. Exhaustion generally means completing the available state-court process before seeking federal review. Because of that status, the court said that any request for discovery should be directed to the state court.
The court also stated that obtaining discovery in connection with the federal petition would require Figueroa to show good cause, meaning a sufficient specific reason for discovery. The court found that he had not yet made that showing.
Ruling
The order did not grant Figueroa's discovery request. It directed that any discovery request should be made in state court and explained that the necessary good-cause showing had not been made for federal discovery. The order did not decide the underlying claims concerning Figueroa's convictions or the alleged evidence-disclosure violations. Judge John G. Koeltl signed the order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.