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S.D.N.Y.Substantive rulingFiled Mar. 22, 2023

Richardson v. Underwood

Judge
Valerie Caproni
Docket
1:18-cv-07694
Court
U.S. District Court · Southern District of New York
Pages
1
HabeasCriminalEvidence
In one sentence

In Richardson v. Capra, Judge Caproni denied habeas relief, rejected the report, and granted a certificate of appealability on the suppression issue.

Who this affects

The petitioner, Mark Richardson, whose request for habeas relief was denied, and Michael Capra, the named defendant.

What happened

In Richardson v. Capra, the court rejected a report and recommendation and denied the petitioner’s request for habeas relief.

The court issued a certificate of appealability because reasonable judges could debate whether the state courts clearly erred in applying Chapple and related decisions instead of Seibert when deciding the petitioner’s suppression motion.

Judge Valerie Caproni also granted the petitioner permission to proceed without paying filing fees for an appeal, and the case was closed.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Richardson v. Underwood · No. 1:18-cv-07694
Judge
Valerie Caproni
Date
Mar. 22, 2023

Background

The opinion text provided is a judgment referring to the court’s Opinion and Order dated March 22, 2023. It identifies Mark Richardson as the petitioner and Michael Capra, superintendent of Sing Sing Correctional Facility, as the defendant. The judgment does not provide the underlying factual details of the habeas petition or the suppression motion.

Ruling

The court rejected the report and recommendation and denied the petitioner’s request for habeas relief. The judgment identifies the issue for possible appeal as whether the state courts clearly erred by applying Chapple and its progeny rather than Seibert when deciding the petitioner’s suppression motion.

Because reasonable jurists could consider that issue debatable, the court issued a certificate of appealability on it. The court also granted the petitioner permission to proceed without paying filing fees for an appeal. The case was closed.

Classification basis

This is classified as a substantive ruling because the judgment denied habeas relief on an issue concerning the state courts’ handling of the suppression motion, rather than disposing of the petition on a stated jurisdictional or other threshold ground.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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