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 said Figueroa must exhaust state remedies before seeking federal relief.
William Figueroa’s federal custody challenge and his request for federal intervention in the state-court proceeding were affected; the order also addressed the need to complete state-court remedies first.
What happened
In Figueroa v. Keyser, William Figueroa asked the federal court to intervene in a state-court matter involving alleged nondisclosure of police reports.
Figueroa alleged that reports containing potentially favorable evidence about another possible shooter had not been disclosed to the defense. He asked the court to order the Kings County District Attorney’s Office to provide two reports.
Judge Koeltl stated that Figueroa’s federal petition was stayed while he exhausted state-court remedies and that he must complete that process before seeking relief from the federal court. The order directed that a copy be mailed to Figueroa.
The detailed version
- Figueroa v. Keyser · No. 1:20-cv-03013
- John Koeltl
- May 28, 2021
Background
William Figueroa sent the court a letter asking it to intervene in a state-court proceeding. His letter alleged that the prosecution had failed to disclose police reports, called DD-5 reports, that he believed contained favorable or exculpatory evidence. He specifically asked the court to order the Kings County District Attorney’s Office to turn over DD-5 reports numbered 176 and 197.
Figueroa also described other reports that he said identified another person as the shooter and stated that some of those reports had not been provided to the defense before trial. He argued that the alleged withholding violated his right to due process and supported relief from his conviction. The opinion does not decide whether these allegations are true or whether the reports were legally required to be disclosed.
Court’s action
Judge Koeltl stated that Figueroa had a federal petition challenging his state-court custody pending before the court. That petition had been stayed while Figueroa exhausted available state-court remedies. The court stated that Figueroa must exhaust those remedies before seeking relief from the federal court and ordered that a copy of the order be mailed to him. The order did not reach the merits of the alleged disclosure violation or expressly state a separate disposition of the request for the reports.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.