United States v. Bulloch

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 27, 2026
Docket24-2975
StatusPublished

This text of United States v. Bulloch (United States v. Bulloch) 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. Bulloch, (2d Cir. 2026).

Opinion

24-2975 United States v. Bulloch

United States Court of Appeals For the Second Circuit

August Term 2025

Argued: September 22, 2025 Decided: January 27, 2026

No. 24-2975

UNITED STATES OF AMERICA,

Appellee,

v.

KENT BULLOCH,

Defendant-Appellant,

WILLIAM YOUNG, SR., a/k/a Bill,

Defendant.

Appeal from the United States District Court for the Eastern District of New York No. 1:20CR00181, Peggy Kuo, Magistrate Judge; Eric R. Komitee, District Judge.

Before: ROBINSON and MERRIAM, Circuit Judges. *

Defendant-appellant Kent Bulloch appeals from a judgment entered in the United States District Court for the Eastern District of New York convicting him, following a jury trial, of a misdemeanor offense of conspiracy to violate a provision of the Defense Production Act of 1950, 50 U.S.C §4512, stemming from his involvement in a scheme during the COVID-19 pandemic to buy personal protective equipment (“PPE”) in bulk and resell it for a profit. See United States v. Bulloch, No. 1:20CR00181(EK)(PK), 2024 WL 4654134 (E.D.N.Y. Nov. 1, 2024).

On appeal, Bulloch argues that the term “accumulate” as used in Section 4512 is interchangeable with the term “hoard” and means “to gather, collect, or accrue over a period of time.” Bulloch contends that the evidence at trial was insufficient to prove that he acquired PPE over a period of time or intended to withhold PPE from the market for a period of time, and that his conviction therefore cannot stand. We disagree with Bulloch on this narrow question of statutory interpretation. Accordingly, we AFFIRM.

JEREMY GUTMAN, New York, NY, for Defendant- Appellant.

ROBERT POLLACK, Assistant United States Attorney (Michael W. Gibaldi, Assistant United States Attorney, on the brief), for Joseph Nocella,

* Circuit Judge Alison J. Nathan was originally a member of the panel but was unable to participate in consideration of this matter. Pursuant to this Court’s Internal Operating Procedures, the appeal was heard and decided by the remaining members of the panel, who are in agreement. See 2d Cir. IOP E(b).

2 Jr., United States Attorney for the Eastern District of New York, Brooklyn, NY, for Appellee.

SARAH A. L. MERRIAM, Circuit Judge:

Defendant-appellant Kent Bulloch appeals from a judgment entered in the

United States District Court for the Eastern District of New York (Kuo, M.J.),

convicting him, following a jury trial before the Magistrate Judge, of a

misdemeanor offense of conspiracy to violate Section 4512 of the Defense

Production Act of 1950 (“DPA”). The conviction stems from Bulloch’s

involvement in a scheme during the COVID-19 pandemic to buy, using money

from investors, personal protective equipment (“PPE”) in bulk and resell it at an

inflated price. Bulloch was sentenced principally to a two-year term of probation

and a fine of $1,000. Bulloch also appeals from an order of the District Judge

(Komitee, D.J.), affirming the judgment entered by the Magistrate Judge. See

United States v. Bulloch, No. 1:20CR00181(EK)(PK), 2024 WL 4654134 (E.D.N.Y.

Nov. 1, 2024).

On appeal, Bulloch argues that the term “accumulate” as used in Section

4512 of the DPA is synonymous with the term “hoard,” which, according to

Bulloch, means “to gather, collect, or accrue over a period of time.” Bulloch Br. at 6

3 (emphasis added). Bulloch requested a jury instruction to that effect, which was

denied. In accordance with his proposed definition, Bulloch contends that the

government had to prove beyond a reasonable doubt that he intended to

withhold scarce materials from the market for a period of time. Bulloch avers

that the evidence at trial was insufficient to prove his intent to withhold PPE –

specifically, KN-95 masks – from the market for a period of time, and thus his

conviction cannot stand. We disagree with Bulloch on this narrow question of

statutory interpretation. Accordingly, we AFFIRM.

I. BACKGROUND

A. Defense Production Act of 1950 and COVID-19 Regulation

Congress passed the DPA, 50 U.S.C. §§4501 et seq., during the Korean War

in an effort “to maintain a large production of military goods while seeking also

to meet the long-denied and increasing needs of the Nation’s civil economy.”

Allen v. Grand Cent. Aircraft Co., 347 U.S. 535, 549 (1954). To that end, the Act

authorizes the President to “allocate materials, services, and facilities in such

manner, upon such conditions, and to such extent as [he or she] shall deem

necessary or appropriate to promote the national defense.” 50 U.S.C. §4511(a)(2).

4 The President may exercise this authority “to control the general distribution of

any material in the civilian market” only if:

the President finds (1) that such material is a scarce and critical material essential to the national defense, and (2) that the requirements of the national defense for such material cannot otherwise be met without creating a significant dislocation of the normal distribution of such material in the civilian market to such a degree as to create appreciable hardship.

Id. §4511(b). With respect to materials that have been designated as scarce and

critical to the national defense, Section 4512, titled “Hoarding of designated

scarce materials,” provides:

In order to prevent hoarding, no person shall accumulate (1) in excess of the reasonable demands of business, personal, or home consumption, or (2) for the purpose of resale at prices in excess of prevailing market prices, materials which have been designated by the President as scarce materials or materials the supply of which would be threatened by such accumulation.

Id. §4512. A willful violation of that section is a misdemeanor punishable by up

to one year in prison and a fine of up to $10,000. See id. §4513.

On March 13, 2020, as the COVID-19 pandemic began to affect the United

States, the President issued Proclamation No. 9994, declaring “that the COVID-19

outbreak in the United States constitutes a national emergency.” Proclamation

No. 9994, 85 Fed. Reg. 15337. Then, as relevant to this appeal, the President

issued two executive orders (“EOs”) pursuant to his authority under, among

5 other things, the DPA. First, on March 18, 2020, the President issued EO 13909,

titled “Prioritizing and Allocating Health and Medical Resources to Respond to

the Spread of COVID-19.” Exec. Order 13909, 85 Fed. Reg. 16227. EO 13909

found: “To ensure that our healthcare system is able to surge capacity and

capability to respond to the spread of COVID-19, it is critical that all health and

medical resources needed to respond to the spread of COVID-19 are properly

distributed to the Nation’s healthcare system and others that need them most at

this time.” Id. Accordingly, the EO concluded “that health and medical

resources needed to respond to the spread of COVID-19, including personal

protective equipment and ventilators, meet the criteria specified in” §4511(b) of

the DPA, id., as “scarce and critical material[s] essential to the national defense,”

§4511(b)(1). The President delegated authority to the Secretary of Health and

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