United States v. Bishop

CourtCourt of Appeals for the Second Circuit
DecidedMarch 23, 2026
Docket25-2157
StatusUnpublished

This text of United States v. Bishop (United States v. Bishop) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Bishop, (2d Cir. 2026).

Opinion

25-2157-cr United States v. Bishop

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 23rd day of March, two thousand twenty-six.

Present: DENNIS JACOBS, RICHARD C. WESLEY, EUNICE C. LEE, Circuit Judges, __________________________________________

UNITED STATES OF AMERICA,

Appellee,

v. No. 25-2157-cr

RONALD BISHOP,

Defendant-Appellant. __________________________________________

For Appellee: MEREDITH A. ARFA, Amy Busa, Assistant United States Attorneys, for Joseph Nocella, Jr., United States Attorney for the Eastern District of New York, Brooklyn, NY.

For Defendant-Appellant: JOSEPH W. RYAN, JR., Huntington, NY.

1 Appeal from a judgment of the United States District Court for the Eastern District of New

York (Azrack, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Defendant-Appellant Ronald Bishop appeals from a July 31, 2025 order denying his

motion for a reduction in sentence pursuant to 18 U.S.C. § 3582(c)(1)(A)(i). On appeal, Bishop

argues that (1) the district court committed plain error by allowing his federal sentence to run

consecutively, rather than concurrently, to his then-undischarged state sentence, and (2) the district

court erred by denying his motion for sentence reduction.

BACKGROUND

In July 2014, Bishop was arrested and charged in Nassau County with several felonies

related to possession and sale of crack cocaine (the “State Case”). While on pretrial release,

Bishop was arrested again in January 2016 on charges that later formed the basis of a federal case:

possession of crack cocaine with the intent to distribute; and unlawful possession of ten illegal

firearms, numerous boxes and bags containing various types of ammunition, and several high-

capacity ammunition feeding devices (the “Federal Case”). Before the Federal Case had

progressed to indictment, Bishop was convicted of the charges in the State Case in July 2016. In

September 2016, a grand jury in the Eastern District of New York returned an indictment charging

Bishop in the Federal Case with (1) conspiracy to distribute substances containing cocaine base

(28 grams or more) and heroin, in or about and between January 2014 and July 2016, in violation

of 21 U.S.C. §§ 846, 841(b)(1)(B)(iii) and 841(b)(1)(C) (Count One); (2) possession with intent

2 to distribute a substance containing cocaine, on or about January 21, 2016, in violation of 21 U.S.C.

§ 841(a)(1) and 841(b)(1)(C) (Count Two); (3) the unlawful possession of firearms, on or about

January 21, 2016, during and in relation to one or more drug trafficking crimes—to wit, the crimes

charged in Counts One and Two—in violation of 18 U.S.C. § 924(c)(1)(A)(i) (Count Three); and

(4) being a felon in possession of a firearm, on or about January 21, 2016, in violation of 18 U.S.C.

§§ 922(g)(1) and 924(a)(2) (Count Four).

In July 2018, while the sentencing in the State Case remained pending, Bishop pleaded

guilty in the Federal Case to Counts One and Three of the federal indictment. 1 At the plea

hearing, neither the government nor the magistrate judge made any representations regarding

whether the federal sentence would run concurrently or consecutively to any state sentence.

In March 2019, the Nassau County court sentenced Bishop in the State Case to an aggregate

term of ten years’ imprisonment and three years’ post-release supervision. Bishop’s counsel

requested that the sentence run concurrently with the as-yet unimposed federal sentence, but the

state court ordered that the term run consecutively to the federal sentence.

Three months later, in June 2019, the district court held Bishop’s federal sentencing

hearing. The Presentence Report (“PSR”) did not address whether the federal sentence would be

imposed concurrently or consecutively to the state sentence and did not address U.S.S.G.

§ 5G1.3(b), but it specified that the conduct underlying the State Case was not treated as “relevant

conduct” under the Guidelines for purposes of the Federal Case. Bishop did not object to this

aspect of the PSR. In July 2019, the district court imposed a total federal sentence of 120 months’

1 On August 22, 2018, the district court accepted the plea entered before the magistrate judge.

3 imprisonment. Like the PSR, the judgment did not specify whether the sentence would run

concurrently or consecutively to the state sentence.

After completing his state sentence, Bishop moved under 18 U.S.C. § 3582(c)(1)(A) for a

reduction of his federal sentence to time served. The district court denied the motion, concluding

that he had not demonstrated extraordinary and compelling reasons and that the § 3553(a) factors

weighed against release. The district court subsequently denied Bishop’s motion for

reconsideration of the denial of his motion for sentence reduction.

DISCUSSION

This Court “typically review[s] the denial of a motion for a discretionary sentence

reduction for abuse of discretion.” United States v. Keitt, 21 F.4th 67, 71 (2d Cir. 2021) (per

curiam). A court abuses its discretion if it “base[s] its ruling on an erroneous view of the law or

on a clearly erroneous assessment of the evidence, or render[s] a decision that cannot be located

within the range of permissible decisions.” United States v. Borden, 564 F.3d 100, 104 (2d Cir.

2009).

Where a defendant forfeits a challenge by “fail[ing] to raise his procedural objections at

the time of sentencing,” this Court reviews for plain error. United States v. Degroate, 940 F.3d

167, 174 (2d Cir. 2019); see also United States v. Villafuerte, 502 F.3d 204, 207-08 (2d Cir. 2007)

(holding that unpreserved challenges to a district court’s sentencing are reviewed for plain error).

Waiver, unlike forfeiture, is the “intentional relinquishment or abandonment of a known

right.” United States v. Olano, 507 U.S. 725, 733 (1993).

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Related

United States v. Borden
564 F.3d 100 (Second Circuit, 2009)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
Aparicio v. Artuz
269 F.3d 78 (Second Circuit, 2001)
United States v. Agrawal
726 F.3d 235 (Second Circuit, 2013)
United States v. Villafuerte
502 F.3d 204 (Second Circuit, 2007)
Gamble v. United States
587 U.S. 678 (Supreme Court, 2019)
United States v. Degroate
940 F.3d 167 (Second Circuit, 2019)
United States v. Keitt
21 F.4th 67 (Second Circuit, 2021)
United States v. Lewis
125 F.4th 69 (Second Circuit, 2025)

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United States v. Bishop, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-bishop-ca2-2026.