United States v. Buyer

CourtCourt of Appeals for the Second Circuit
DecidedMarch 19, 2025
Docket23-7202
StatusUnpublished

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

Opinion

23-7202-cr (L) United States v. Buyer

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUM- MARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FED- ERAL 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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held at the 2 Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3 19th day of March, two thousand twenty-five. 4 5 Present: 6 DEBRA ANN LIVINGSTON, 7 Chief Judge, 8 DENNIS JACOBS, 9 GUIDO CALABRESI, 10 Circuit Judges. 11 _____________________________________ 12 13 UNITED STATES OF AMERICA, 14 15 Appellee, 16 17 v. 23-7202-cr (Lead) 18 23-7745 (Con) 19 20 STEPHEN BUYER, AKA Sealed Defendant 1, 21 22 Defendant-Appellant. 23 _____________________________________ 24 25 For Appellee: MARGARET GRAHAM, Assistant United States Attorney 26 (Jacob R. Fiddelman, on the brief), for Matthew Po- 27 dolsky, United States Attorney for the Southern District 28 of New York, New York, NY. 29 30 For Defendant-Appellant: DANIEL A. RUBENS (Daniel R. Alonso, Alyssa Barnard- 31 Yanni & Elizabeth A. Bixby, on the brief), Orrick, Her- 32 rington & Sutcliffe LLP, New York, NY. 33 1 1 Appeal from a judgment of the United States District Court for the Southern District of

2 New York (Berman, J.).

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

4 DECREED that the judgment of the district court is AFFIRMED.

5 Defendant-Appellant Stephen Buyer (“Buyer”) appeals from a judgment of the United

6 States District Court for the Southern District of New York (Berman, J.), convicting him, after a

7 nine-day jury trial, of two counts of securities fraud in violation of 15 U.S.C. §§ 78j(b) and 78ff,

8 17 C.F.R. § 240.10b-5, and 18 U.S.C. § 2; and two counts of securities fraud in violation of 18

9 U.S.C. § 1348 and 2. The jury concluded that Buyer misappropriated material nonpublic infor-

10 mation (“MNPI”) from two of his consulting clients and then used that information for illegal

11 insider trading. Specifically, in 2018, Buyer learned from Anthony Russo (“Russo”), an execu-

12 tive at T-Mobile U.S. Inc. (“T-Mobile”), that T-Mobile was planning to acquire Sprint Corp.

13 (“Sprint”). Buyer then used this information to buy Sprint stock before the merger was publicly

14 disclosed and sell that stock for a profit of more than $126,000 after the merger was announced.

15 And in 2019, Buyer learned from Christopher Stansbury (“Stansbury”), an employee at

16 Guidehouse, Inc. (“Guidehouse”), that it was planning to acquire Navigant Consulting Inc. (“Nav-

17 igant”). Buyer similarly used this information to trade in Navigant stock, this time realizing over

18 $227,000 in profits. The district court sentenced Buyer principally to 22 months’ imprisonment,

19 to be followed by three years’ supervised release, and imposed forfeiture of $354,027.72. Buyer

20 contests his convictions by challenging the district court’s evidentiary rulings, venue in the South-

21 ern District of New York (“SDNY”), and the sufficiency of the evidence. We assume the parties’

22 familiarity with the facts and procedural history of the case, which we summarize only as necessary

23 to explain our decision to AFFIRM.

2 1 I. Evidentiary Rulings

2 Buyer objects to the admission of a report generated using a software called Cellebrite and

3 containing the extracted contents of Stansbury’s cellphone (the “Cellebrite Report”) and to the

4 testimony of FBI digital forensic examiner Jessica Volchko (“Volchko”), who authenticated and

5 explained the Cellebrite Report. Buyer argues that (1) the admission of the Cellebrite Report

6 without the testimony of the analyst who created the report violated his rights under the Confron-

7 tation Clause; (2) the Cellebrite Report was insufficiently authenticated to be admitted at trial; and

8 (3) Volchko’s testimony was improperly admitted as lay witness testimony rather than expert opin-

9 ion testimony.

10 A. Standards of Review

11 We review objections to evidentiary rulings based on “[a]lleged violations of the Confron-

12 tation Clause . . . de novo.” United States v. Jass, 569 F.3d 47, 55 (2d Cir. 2009) (alterations in

13 original) (quoting United States v. Vitale, 459 F.3d 190, 195 (2d Cir. 2006)). In general, however,

14 “[t]his Court reviews evidentiary rulings for abuse of discretion,” United States v. Cummings, 858

15 F.3d 763, 771 (2d Cir. 2017), “revers[ing] . . . only when an evidentiary ruling is manifestly erro-

16 neous or arbitrary and irrational,” United States v. Dawkins, 999 F.3d 767, 788 (2d Cir. 2021)

17 (internal quotations and citations omitted). But when a defendant “fails to preserve an eviden-

18 tiary challenge by lodging a timely objection”—including by failing to timely object to the admis-

19 sion of evidence on Confrontation Clause grounds—“we review for plain error.” Cummings, 858

20 F.3d at 771 (quoting United States v. Certified Env’t Servs., Inc., 753 F.3d 72, 96 (2d Cir. 2014));

21 see also United States v. Dukagjini, 326 F.3d 45, 59–60 (2d Cir. 2003) (reviewing “the district

22 court’s admission of testimony in violation of the Confrontation Clause for plain error”). And

23 further, we will not overturn a conviction because of an evidentiary error if we conclude that error

3 1 was harmless. United States v. Abreu, 342 F.3d 183, 190 (2d Cir. 2003); see also Fed. R. Crim.

2 P. 52(a).

3 B. Buyer Failed to Preserve His Confrontation Clause Objection Below

4 “To preserve an evidentiary claim on appeal, a party must ‘timely object[]’ and ‘state[] the

5 specific ground, unless it [is] apparent from context.’” 1 United States v. Williams, 930 F.3d 44,

6 64 (2d Cir. 2019) (alterations in original) (quoting Fed. R. Evid. 103(a)). When a party objects

7 to the admission of evidence at trial but does not state the specific grounds, “he fail[s] to preserve

8 that claim for appeal” and we “review it only for plain error.” See United States v. Inserra, 34

9 F.3d 83, 90 n.1 (2d Cir. 1994).

10 “To be timely, an objection . . . must be ‘made as soon as the ground of it is known, or

11 reasonably should have been known to the objector.’” United States v. Yu-Leung, 51 F.3d 1116,

12 1120 (2d Cir. 1995) (quoting Hutchinson v.

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