Cardello-Smith v. Director, Metropolitan Detention Center, Brooklyn New York
1:25-cv-03498
| S.D.N.Y. | Jul 15, 2025Background
- Derrick Lee Cardello-Smith, currently incarcerated in Michigan, filed a pro se habeas corpus petition on behalf of Sean John Combs (“Puff Daddy”) under 28 U.S.C. § 2241.
- The petition was filed against the Director of the Metropolitan Detention Center, Brooklyn, New York, as respondent.
- Cardello-Smith was not seeking relief for himself, but purported to act as “next friend” to Combs.
- The court considered whether Cardello-Smith had standing to bring a petition on Combs' behalf.
- The petition did not include facts showing why Combs could not file on his own or describing the relationship between Cardello-Smith and Combs.
- The court reviewed the sufficiency of the “next friend” status and denied the petition for lack of standing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing as ‘next friend’ under § 2241 | Cardello-Smith can petition on behalf of Combs | Cardello-Smith lacks standing as ‘next friend’ | No standing; petition denied |
| Need for explanation why real party can't sue | No explanation given | Failure to allege Combs is unable to file | No showing; petition denied |
| Requirement for significant relationship | No facts pled regarding relationship with Combs | No evidence of significant relationship | No relationship; petition denied |
| Substantial showing of constitutional violation | Petition implies violation but lacks substance | Petition contains no substantial constitutional claim | No substantial showing; no certificate |
Key Cases Cited
- Whitmore v. Arkansas, 495 U.S. 149 (1990) (elucidates requirements for “next friend” standing in habeas petitions)
- Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (requires liberal construction of pro se pleadings)
- Ross ex rel. Dunham v. Lantz, 408 F.3d 121 (2d Cir. 2005) (denies "next friend" status without evidence of incompetence/disability or inability to sue)
- Green v. United States, 260 F.3d 78 (2d Cir. 2001) (clarifies pro se pleading standards)
- Coppedge v. United States, 369 U.S. 438 (1962) (sets the good faith standard for granting in forma pauperis status on appeal)