United States v. Connearney

CourtCourt of Appeals for the Second Circuit
DecidedMay 28, 2026
Docket25-15
StatusUnpublished

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

Opinion

25-15-cr United States v. Connearney

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 28th day of May, two thousand twenty-six. Present: AMALYA L. KEARSE, WILLIAM J. NARDINI, EUNICE C. LEE, Circuit Judges. _____________________________________ UNITED STATES OF AMERICA, Appellee, v. 25-15-cr MARTIN CONNEARNEY,

Defendant-Appellant.

_____________________________________

For Appellee: RAJIT S. DOSANJH (Benjamin S. Clark, on the brief), Assistant United States Attorneys, for John A. Sarcone III, United States Attorney for the Northern District of New York, Syracuse, NY

For Defendant-Appellant: JAMES P. EGAN, Assistant Federal Public Defender, Federal Public Defender’s Office, Northern District of New York, Syracuse, NY

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

New York (Anne M. Nardacci, District Judge).

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

DECREED that the judgment of the district court be AFFIRMED.

Defendant-Appellant Martin Connearney appeals from a criminal judgment of the United

States District Court for the Northern District of New York entered on December 20, 2024,

following a guilty plea.

In April 2022, Martin Connearney messaged a man, whom he believed to be a single father,

on the “FetLife” app. On the app, the single father claimed to have a ten-year-old daughter with

hearing and speech issues, and advertised that he was looking for “a mentor” who could “teach”

his daughter to “share our kinks.” Connearney messaged the man to express his interest in having

a sexual relationship with the young girl. After several weeks of correspondence, which included

explicit text messages, photos, and phone calls, it was arranged that Connearney would move from

Massachusetts to New York to live with the man and his daughter. Unbeknownst to Connearney,

the “single father” he was messaging was actually an undercover law enforcement officer, and the

daughter did not exist. While in transit to the undercover officer’s purported home, Connearney

stopped at a gas station where he was immediately arrested.

Thereafter, Connearney was charged in a one-count indictment with traveling with intent

to engage in illicit sexual conduct, in violation of 18 U.S.C. § 2423(b) and (f)(1). He pled guilty

to the indictment pursuant to a written plea agreement. The district court sentenced Connearney

to 151 months of imprisonment, to be followed by twenty years of supervised release.

On appeal, Connearney argues that the district court’s imposition of a 151-month prison

sentence was procedurally unreasonable because: (1) the district court erred in imposing U.S.S.G.

2 § 3A1.1’s vulnerable victim adjustment, where the victim of the crimes was fictitious; and (2) the

district court relied on a factually inaccurate assessment of his criminal history when fashioning

his sentence. We assume the parties’ familiarity with the case.

I. The District Court’s Application of the Vulnerable Victim Adjustment

The Sentencing Guidelines provide for a two-level adjustment to a defendant’s base

offense level if “the defendant knew or should have known that a victim of the offense was a

vulnerable victim.” U.S.S.G. § 3A1.1(b)(1) (2024). The Guidelines define a vulnerable victim as

a person “who is unusually vulnerable due to age, physical or mental condition, or who is otherwise

particularly susceptible to the criminal conduct.” Id. cmt. 2. This Court has held that “Section

3A1.1(b) does not require that the defendant select the victim because of his or her vulnerability –

it is sufficient that he knew or should have known of this quality when deciding to go ahead with

the crime.” United States v. McCall, 174 F.3d 47, 50 (2d Cir. 1998) (applying identically worded

version of § 3A1.1(b)(1) in 1998 Guidelines Manual). 1 This enhancement reflects “the public

interest in more severely punishing those whose choice of victim demonstrates an extra measure

of criminal depravity.” United States v. Hershkowitz, 968 F.2d 1503,1505 (2d Cir. 1992). Here,

in finding that this two-level adjustment should be applied to Connearney’s base offense level, the

district court highlighted that Connearney “appeared to become more comfortable with traveling

for the sexual encounter after hearing voice recordings of the purported deaf and speech-impaired

child,” as it “made him more comfortable that she may not be able to disclose the abuse due to her

disability.” Dist. Ct. Dkt. No. 64 at 4. In other words, the district court found that Connearney

knew of his prospective victim’s vulnerabilities and, based in part on those vulnerabilities, chose

1 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted.

3 to travel to engage in sexual conduct with her. Connearney did not challenge the application of

this adjustment to his base offense level before this appeal.

“When a party fails to raise an objection to a purported error below, any subsequent

challenge may be deemed either waived through explicit abandonment or forfeited through failure

to object.” United States v. Cooper, 131 F.4th 127, 130 (2d Cir. 2025). If the failure to raise the

challenge below was unintentional, we find the claim forfeited and reviewable on appeal for plain

error. Id. But if the failure to object was deliberate, the claim is waived and “not entitled to

appellate review.” Id. Here, the parties dispute whether Connearney merely forfeited the claim,

or whether instead it was waived.

The record before us compels the conclusion that Connearney waived any objection to the

application of § 3A1.1’s adjustment to his base offense level. Connearney was first made aware

that § 3A1.1(b)’s adjustment would be applied to his base offense level in the initial Presentence

Report (“PSR”) prepared by the probation office. Connearney did not object to the application of

the adjustment in his response to the initial PSR, or to any subsequent addendum. Moreover, in

its sentencing memorandum, the Government argued that § 3A1.1’s enhancement applied even

when the victim is fictitious. Then, despite having received the Government’s sentencing

memorandum more than seven months prior, Connearney did not address, or even mention, the

applicability of § 3A1.1’s vulnerable victim adjustment in his own sentencing memorandum, let

alone object to its application.

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Related

Puckett v. United States
556 U.S. 129 (Supreme Court, 2009)
United States v. Howard Hershkowitz
968 F.2d 1503 (Second Circuit, 1992)
United States v. Nelson A. McCall
174 F.3d 47 (Second Circuit, 1998)
United States v. Pattee
820 F.3d 496 (Second Circuit, 2016)
United States v. Marcus
176 L. Ed. 2d 1012 (Supreme Court, 2010)
United States v. Helm
58 F.4th 75 (Second Circuit, 2023)
United States v. Cooper
131 F.4th 127 (Second Circuit, 2025)

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