United States v. Bullock

CourtCourt of Appeals for the Second Circuit
DecidedAugust 22, 2025
Docket23-7341
StatusPublished

This text of United States v. Bullock (United States v. Bullock) 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. Bullock, (2d Cir. 2025).

Opinion

23-7341 United States v. Bullock

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

August Term 2024

(Argued: November 21, 2024 Decided: August 22, 2025)

No. 23-7341

––––––––––––––––––––––––––––––––––––

UNITED STATES OF AMERICA,

Appellee,

-v.-

RANDOLPH BULLOCK,

Defendant-Appellant.

Before: LIVINGSTON, Chief Judge, JACOBS, and MENASHI, Circuit Judges.

Defendant-Appellant Randolph Bullock (“Bullock”) appeals from a judgment of the United States District Court for the Northern District of New York (Suddaby, J.) convicting him, following his guilty plea, of possessing child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B). On appeal, Bullock argues that the district court erred in calculating his offense level by applying a five-level enhancement for “engag[ing] in a pattern of activity involving the sexual abuse or exploitation of a minor.” U.S.S.G. § 2G2.2(b)(5). Section 2G2.2(b)(5)’s pattern of abuse enhancement applies if a defendant has engaged in “any combination of

1 two or more separate instances of the sexual abuse or sexual exploitation of a minor.” U.S.S.G. § 2G2.2 cmt. n.1 (emphasis added). The district court found by a preponderance of the evidence that on September 14, 2014, Bullock abused two children at his church. The two acts of abuse were separated by non-criminal conduct and occurred in different rooms of the building. Bullock contends that the district court erred in applying the pattern enhancement on these facts because his offenses that day constitute only a single “instance” of sexual abuse. We disagree. Relying by analogy on the Supreme Court’s analysis in Wooden v. United States, 595 U.S. 360 (2022), we conclude that Bullock’s acts constitute two separate instances of sexual abuse and that the district court therefore did not err in applying the § 2G2.2(b)(5) pattern of abuse enhancement.

Bullock also challenges the substantive reasonableness of his 97-month sentence and the procedural reasonableness of special conditions of supervised release restricting his contact with minors, limiting him to a single internet-capable device, and prohibiting him from viewing or possessing sexually explicit material. We hold that Bullock’s sentence is not substantively unreasonable and that the district court did not err in imposing the challenged special conditions.

Accordingly, the judgment of the district court is AFFIRMED.

FOR APPELLEE: Joshua Rothenberg, Assistant United States Attorney, for Carla B. Freedman, United States Attorney for the Northern District of New York, Syracuse, NY.

FOR DEFENDANT-APPELLANT: Paul James Angioletti, Staten Island, NY.

DEBRA ANN LIVINGSTON, Chief Judge:

Defendant-Appellant Randolph Bullock (“Bullock”) appeals from a

judgment of the United States District Court for the Northern District of New York

(Suddaby, J.), entered on September 28, 2023, convicting him, following his guilty

2 plea, of three counts of possessing child pornography in violation of 18 U.S.C.

§ 2252A(a)(5)(B). The district court sentenced Bullock principally to 97 months’

imprisonment to be followed by a 20-year term of supervised release.

On appeal, Bullock argues that the district court erred by applying a five-

level enhancement to his offense level pursuant to U.S.S.G. § 2G2.2(b)(5), which

applies when a defendant has “engaged in a pattern of activity involving the

sexual abuse or exploitation of a minor.” Bullock, who molested two boys after

church services in 2014, contends that his actions do not constitute a pattern

because he did not engage in “two or more separate instances of . . . sexual abuse.”

U.S.S.G. § 2G2.2 cmt n.1. According to Bullock, he abused his two victims during

a single instance, and thus the pattern enhancement should not apply. Bullock

also contends that his sentence was substantively unreasonable and that the

district court procedurally erred when imposing special conditions of supervised

release restricting his contact with minors, limiting him to a single internet-capable

device, and prohibiting him from viewing or possessing any material depicting

sexually explicit conduct.

We disagree. We first conclude that the district court appropriately applied

§ 2G2.2(b)(5)’s pattern enhancement. In considering what constitutes an instance

3 of sexual abuse, we find instructive the Supreme Court’s analysis in Wooden v.

United States, 595 U.S. 360 (2022). In determining whether criminal acts occurred

on separate occasions for the purposes of 18 U.S.C. § 924(e)(1), Wooden considered:

(1) whether the offenses were “committed close in time, in an uninterrupted course

of conduct,” (2) whether the offenses occurred in close geographic “[p]roximity,”

and (3) the degree to which “the conduct giving rise to the offenses” was “similar

or intertwined” such that it indicated “a common scheme or purpose.” Id. at 369.

Here, Bullock molested a six-year-old boy in the pastor’s office of his church after

services on September 14, 2014. Later that day, after counting the donations the

church had received, Bullock molested a four-year-old boy in a church classroom.

The district court found that Bullock acted opportunistically in sexually abusing

the two victims, in different places and at different times separated by intervening

non-criminal conduct. By analogy to Wooden, this cannot reasonably be deemed a

single instance of criminal conduct.

We also conclude that Bullock’s sentence is not substantively unreasonable,

that the district court sufficiently justified the imposition of the challenged special

conditions, and that those special conditions are amply supported by the record.

We therefore AFFIRM the judgment of the district court.

4 BACKGROUND

Bullock began looking at inappropriate images of children in the 1980s and

continued to do so, at least intermittently, for the ensuing three decades. The

investigation leading to Bullock’s instant conviction began when Bullock’s

coworkers reported him for viewing what appeared to be child pornography at

work in 2018. A forensic analysis of Bullock’s work devices proved the accusations

credible, and Bullock was fired. Bullock then self-referred to a 75-day residential

treatment program designed to help people with sexual compulsions, and he

continued to receive outpatient services after its completion. The treatment

proved unsuccessful. Bullock—who was by this point under investigation for

suspected possession of child pornography—was seen publicly viewing

inappropriate images of children on a public library computer in November 2018

and again in April 2021. A subsequent search of Bullock’s personal computers

revealed that he possessed between 10 and 150 images of child pornography as

well as a large number of images indicating a sexual interest in children but not

strictly meeting the definition of child pornography.

On June 17, 2022, a grand jury charged Bullock with three counts of

possessing child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B). Bullock

pleaded guilty to all three counts pursuant to a plea agreement. In the plea

5 agreement, the parties stipulated to a variety of Guidelines provisions but noted a

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