Williams v. Lamanna
- Kenneth Karas
- 7:18-cv-02172-KMK-JCM
- U.S. District Court · Southern District of New York
- 4
In Williams v. Lamanna, Judge Karas dismissed Williams’s habeas petition after adopting a report recommending denial, finding no clear error.
Michael Williams, whose federal challenge to his New York convictions was dismissed; Jaime Lamanna was the respondent.
What happened
In Williams v. Lamanna, Michael Williams asked a federal court to review his New York convictions for drug possession and sale. He challenged several trial and sentencing issues, including courtroom access, his absence during testimony, the prosecution’s closing argument, a discharged juror, and the combined effect of alleged errors.
A judge recommended denying the petition after concluding that Williams’s constitutional rights were not violated and that his sentencing claim did not present a federal constitutional issue. Williams did not object to that recommendation. The court reviewed it for clear error, meaning an obvious mistake, and found none.
Judge Kenneth M. Karas adopted the recommendation in its entirety and dismissed the petition. The court also said that no certificate allowing an appeal would issue, certified that any appeal would not be taken in good faith, and directed the clerk to close the case.
The detailed version
- Williams v. Lamanna · No. 7:18-cv-02172-KMK-JCM
- Kenneth Karas
- Mar. 25, 2024
Background
Following a jury trial in Dutchess County Court, Michael Williams was convicted of four counts of criminal possession of a controlled substance in the third degree and four counts of criminal sale of a controlled substance in the third degree. He received consecutive ten-year prison terms connected to offenses on July 15 and July 16, 2010, for a total of twenty years, followed by three years of post-release supervision.
The New York Appellate Division, Second Department, affirmed the conviction, and the New York Court of Appeals denied leave to appeal. Williams later filed a motion to vacate the judgment under New York Criminal Procedure Law § 440.10. The Dutchess County Court denied that motion, and Williams did not appeal that decision.
Williams then filed this petition under 28 U.S.C. § 2254, a federal procedure allowing a state prisoner to challenge custody based on an alleged violation of federal law or the Constitution. The petition was referred to Judge Judith C. McCarthy, who issued a report and recommendation on October 11, 2023.
Issues and Recommendation
The report recommended denying the petition in its entirety. It concluded that:
- Williams’s right to a public trial was not violated when family members and friends were temporarily excluded from the courtroom. - The trial court did not violate his right to be present by proceeding without him on the last day of testimony after he admittedly jumped bail. - The prosecution’s statements and use of slides during closing argument did not deprive him of a fair trial. - Williams did not raise a cognizable federal constitutional issue concerning his sentence. - The trial judge did not violate his constitutional rights by discharging a juror who agreed she could not be fair and impartial. - The combined effect of the alleged errors did not make his conviction constitutionally invalid.
Williams filed no objections to the report and recommendation. When there are no objections, the court reviews a dispositive recommendation for clear error, meaning an obvious mistake after reviewing the record.
Ruling
The court carefully reviewed the report and recommendation and the petition and found no substantive error, clear or otherwise. Judge Kenneth M. Karas therefore adopted the report and recommendation in its entirety.
The order dismissed the petition. It also ordered that a certificate of appealability would not issue because Williams had not made a substantial showing that a constitutional right was denied. A certificate of appealability is a court authorization required for an appeal in this type of proceeding. The court further certified that any appeal from the order would not be taken in good faith and directed the clerk to close the case and mail Williams a copy of the order.
Classification note
This is classified as a procedural order because the court’s own action was to adopt the report and recommendation after clear-error review and dismiss the petition without conducting an independent merits analysis in the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.