Michael Maietta v. Christopher Artuz, Superintendent, Greenhaven Correctional Facility

Summary

The Second Circuit affirmed the denial of Michael Maietta's federal habeas corpus petition challenging the use of a post-plea arrest to impose the maximum sentence under an earlier plea agreement. The court held that Maietta's guilty plea to the subsequent Westchester burglary charge precluded him from contesting, for purposes of the earlier sentencing agreement, the identity of the perpetrator and validity of the arrest.

Holdings

1. In the circumstances presented, Maietta's guilty plea and resulting conviction on the Westchester charge precluded his challenge to the validity of the arrest for the limited purpose of determining whether he breached the plea agreement governing the Bronx charges.

Questions Presented

1. Whether Maietta's guilty plea and resulting conviction on the Westchester burglary charge precluded him from challenging the validity of the arrest for the limited purpose of determining whether he breached the Bronx plea agreement.
2. Whether the state sentencing court violated due process by failing to conduct a full evidentiary hearing concerning the validity of the Westchester arrest.

Disposition

affirmed