Jones v. Hallett

Background

Rafael A. Jones, who was incarcerated on Rikers Island and proceeded without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging ongoing proceedings in Bronx County Criminal Court. On February 25, 2021, the court denied that petition under the rule from Younger v. Harris, which generally limits federal-court interference with ongoing state criminal proceedings. The earlier denial was stated to be without prejudice to a later § 2254 petition if Jones were convicted, and the court instructed him to first use available state-court remedies.

Submissions at Issue

Jones filed nine submissions challenging the February 25 order: a motion for production of documents; a motion for reconsideration under Federal Rule of Civil Procedure 60(b); a request to stay eviction proceedings involving his New York apartment; a request for an injunction concerning delivery of legal mail; a motion for review of evidence; two notices about alleged violations in his state criminal case; a request for a mandamus order; and an amicus filing concerning his criminal case. He also filed two additional petitions under § 2254 seeking release.

Rule 60(b) Motion

The court denied reconsideration under Rule 60(b). It explained that this rule can provide relief from a habeas proceeding’s denial only when the motion attacks the integrity of that federal proceeding, rather than the underlying criminal case. Jones challenged his ongoing state-court proceedings, not the integrity of the federal proceeding, so the court denied the motion.

Two New § 2254 Petitions

The court construed Jones’s two new § 2254 petitions as applications for permission to amend the earlier petition. It denied leave to amend for the same reason it had denied the original petition: Jones had not alleged special circumstances showing bad faith, harassment, or serious and immediate irreparable injury in the ongoing criminal proceedings.

The court noted that Jones described his detention as a kidnapping, but New York State records attributed his current incarceration to an arrest for assault with intent to cause physical injury under New York Penal Law § 120.00. The opinion also identified a pending Bronx Criminal Court matter, People v. Jones, No. 2020BX001289, with a next court date scheduled for June 9, 2021.

The court further stated that complaints about confinement conditions must be brought in a civil action under 42 U.S.C. § 1983, rather than in a petition challenging the legality or duration of confinement. In a footnote, it applied the same reasoning to Jones’s eviction-related allegations and stated that it was expressing no view about the merits of any eviction challenge he might bring in Housing Court.

Disposition

Judge Louis L. Stanton denied the motion for reconsideration. He also denied the remaining motions as moot, and construed the two § 2254 petitions as motions for leave to file a § 2254 petition before denying leave to amend. The court closed the case under Docket No. 20-CV-10350 and directed the Clerk to mail the order to Jones and record service. The court stated that it would accept only documents directed to the United States Court of Appeals for the Second Circuit.