15 N.Y.2d 751 (1965)
A writ of habeas corpus will be denied if the petition lacks sufficient factual support to warrant relief, especially when challenging a conviction without a direct appeal.
Summary
Lilly Harris sought a writ of habeas corpus, arguing that her conviction for failing to operate the heating system in her multiple dwelling violated due process. Harris claimed she was financially unable to maintain the heating system due to reduced rents of $1 per apartment. The New York Court of Appeals affirmed the dismissal of her writ, holding that her petition was too factually sparse to justify relief. The court emphasized that Harris did not appeal her initial conviction, and habeas corpus was not the appropriate remedy given the lack of detailed factual allegations. The affirmance was without prejudice, allowing Harris to pursue other legal avenues if warranted by more substantial facts.
Facts
Lilly Harris owned or managed a multiple dwelling and was convicted for failing to operate its heating system, a violation of New York law. She asserted that she couldn’t afford to operate the heating system because the rents in her building had been reduced to $1 per apartment. She did not appeal her conviction directly.
Procedural History
Harris sought to challenge her conviction via a writ of habeas corpus, claiming a violation of due process. The lower court dismissed the writ. Harris appealed this dismissal to the New York Court of Appeals.
Issue(s)
Whether a petition for a writ of habeas corpus can be granted when the petition lacks sufficient factual detail to support the claim that the underlying conviction violated due process.
Holding
No, because the petition was too sparse in its statements of fact to serve as the foundation for any relief.
Court’s Reasoning
The Court of Appeals found that Harris’s petition for habeas corpus lacked the necessary factual foundation to warrant relief. The court noted that Harris was essentially arguing that she was convicted for failing to do the impossible, which she claimed was a denial of due process. However, the court emphasized that she did not appeal her original conviction. The court implied that habeas corpus is not a substitute for a direct appeal, especially when the factual basis for the constitutional claim is weakly presented. The court’s decision highlights the importance of providing detailed and specific factual allegations in a habeas corpus petition, particularly when challenging a conviction on constitutional grounds. The court did not foreclose the possibility of future legal action, stating that the affirmance was “without prejudice to her position in any new action or proceeding if the facts warrant such relief.”