Matter of Sellers v. Stanford
Khaliyq Sellers, convicted of first-degree assault, had his parole revoked by the New York State Board of Parole after violating release conditions at a drug treatment center and during detention at Rikers Island. The violations included making verbal threats to "blow up the place" and threatening to kill everyone at Rikers Island, among other non-compliant behaviors. Sellers initiated a CPLR article 78 proceeding, challenging the revocation on grounds of untimeliness and due process violations, which was transferred to the Appellate Division. The Appellate Division, Second Department, denied the petition and dismissed the proceeding on the merits, concluding that the Board's determination was supported by substantial evidence. The court specifically found that verbal threats constituted prohibited behavior under parole rule 8, without requiring physical conduct, and that the final parole revocation hearing was timely held.