United States v. Coonan

143 F.4th 119
CourtCourt of Appeals for the Second Circuit
DecidedJuly 9, 2025
Docket24-2119
StatusPublished

This text of 143 F.4th 119 (United States v. Coonan) 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. Coonan, 143 F.4th 119 (2d Cir. 2025).

Opinion

24-2119 United States v. Coonan

In the United States Court of Appeals For the Second Circuit

August Term, 2024

(Argued: May 16, 2025 Decided: July 9, 2025)

Docket No. 24-2119

UNITED STATES OF AMERICA,

Appellee,

–v.–

JAMES COONAN,

Defendant-Appellant,

KEVIN KELLY, JAMES MCELROY, KENNETH SHANNON, WILLIAM BOKUM, JOHN HALO, EDNA COONAN, RICHARD RITTER, FLORENCE COLLINS, THOMAS COLLINS,

Defendants. *

Before: LYNCH, PARK, and ROBINSON, Circuit Judges.

* The Clerk of Court is respectfully directed to amend the caption on this Court’s docket to be consistent with the caption on this opinion. Appellant James Coonan appeals from an order of the United States District Court for the Southern District of New York (Gardephe, J.) denying his motion for sentence reduction pursuant to 18 U.S.C. § 3582(c)(1). Coonan has been serving a lengthy prison sentence for crimes committed between the mid-1960s and the mid-1980s.

The Sentencing Reform Act of 1984, including the provision codified at 18 U.S.C. § 3582(c)(1), is inapplicable in cases that arise from conduct occurring before November 1, 1987. The First Step Act of 2018 changed some aspects of § 3582(c)(1) but did not change the Sentencing Reform Act’s limitations on the applicability of § 3582(c)(1). So Coonan is ineligible for relief under 18 U.S.C. § 3582(c)(1). Accordingly, we AFFIRM.

JERRY J. FANG (Michael D. Maiman, on the brief), Assistant United States Attorneys, for Danielle R. Sassoon, United States Attorney for the Southern District of New York, New York, NY.

ANGELA D. LIPSMAN (Joseph R. Corozzo, on the brief), Rubinstein & Corozzo, LLP, New York, NY, for Defendant-Appellant.

ROBINSON, Circuit Judge:

Appellant James Coonan appeals from an order of the United States District

Court for the Southern District of New York (Gardephe, J.) denying his motion for

sentence reduction pursuant to 18 U.S.C. § 3582(c)(1). 1 Coonan’s appeal presents

1 Such motions are sometimes colloquially identified as “compassionate release” motions. We have recognized that this term is a misnomer, as the statute allows for sentence reductions, and not simply release. See United States v. Brooker, 976 F.3d 228, 237 (2d Cir. 2020). We treat the terms “compassionate release” and “sentence reduction” as interchangeable and primarily use the latter term that more precisely reflects the scope of the statute.

2 a single, narrow question: Whether inmates serving federal prison time for

conduct that occurred prior to November 1, 1987, may seek a sentence reduction

under 18 U.S.C. § 3582(c)(1), as amended by the First Step Act of 2018. We hold

that they may not and AFFIRM.

BACKGROUND

Appellant James Coonan was once the leader of the “Westies,” an Irish-

American gang active in the Hell’s Kitchen neighborhood of Manhattan between

the mid-1960s and the mid-1980s. Coonan and the Westies profited from illegal

loansharking, extortion, gambling, counterfeiting, and narcotics, and they

protected their power and influence through violence, including murder. The

United States government indicted Coonan and nine co-defendants on September

17, 1987, for (among other things) participating and conspiring to participate in a

racketeering enterprise in violation of 18 U.S.C. § 1962. At trial, a jury convicted

Coonan of ten charges and acquitted on one. Taking into account mandatory

consecutive terms of imprisonment, the district court imposed a total sentence of

75 years. Coonan has now served approximately 38 years.

Over the course of his time in prison, Coonan has appeared at least three

times before the United States Parole Commission to request parole: in 2012, 2021,

and 2023. The Parole Commission has never granted Coonan parole. According

3 to the Bureau of Prisons, Coonan is projected to be released on mandatory release

on June 1, 2030.

Separate from the parole process, Coonan asked the Bureau of Prisons

(“BOP”) to file a sentence reduction motion on his behalf in December 2020,

several years before Coonan filed his own § 3582(c)(1) motion at the heart of this

case. The BOP denied Coonan’s request and his administrative appeal of that

denial.

In August 2023, Coonan filed his own motion seeking a sentence reduction

pursuant to § 3582(c)(1)(A) in the United States District Court for the Southern

District of New York. The district court denied Coonan’s motion on the ground

that Coonan could not move for compassionate release under § 3582(c)(1). United

States v. Coonan, No. 87-CR-249, 2024 WL 3567520, at *3–4 (S.D.N.Y. June 26, 2024).

The district court explained that § 3582 is a component of the Sentencing Reform

Act of 1984, and the sentencing reforms in that statute apply only to sentences

arising from offenses committed on or after November 1, 1987. Id. The court

concluded that inmates like Coonan, who committed their offenses before

November 1, 1987, cannot seek a sentence reduction under § 3582(c)(1), even after

that section was amended in 2018 to give inmates the right to bring their own

§ 3582 motions. Id. at *4–5. Coonan timely appealed the district court’s order.

4 DISCUSSION

We have jurisdiction to review the district court’s final order denying

compassionate release. See 28 U.S.C. § 1291. Generally, “[w]e review the denial

of a motion for compassionate release for abuse of discretion,” but we review

“underlying matters of statutory interpretation” without any deference to the

district court’s reasoning. United States v. Halvon, 26 F.4th 566, 569 (2d Cir. 2022). 2

Coonan seeks a sentence reduction pursuant to § 3582(c)(1), which says:

The court may not modify a term of imprisonment once it has been imposed except that—(1) in any case—(A) the court, upon motion of the Director of the Bureau of Prisons, or upon motion of the defendant [after exhausting administrative remedies], may reduce the term of imprisonment . . . after considering the factors set forth in section 3553(a) to the extent that they are applicable, if it finds that—(i) extraordinary and compelling reasons warrant such a reduction . . . and that such a reduction is consistent with applicable policy statements issued by the Sentencing Commission[.]

18 U.S.C. § 3582(c)(1) (as amended). The pivotal question in this case is whether

§ 3582(c)(1) applies in Coonan’s case.

Coonan says yes. He emphasizes that the statute specifically says that a

court may reduce the term of imprisonment upon motion of the defendant “in any

case.” And he contends that we should adopt his interpretation to avoid

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rodriguez v. United States
480 U.S. 522 (Supreme Court, 1987)
Mistretta v. United States
488 U.S. 361 (Supreme Court, 1989)
United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
Clark v. Martinez
543 U.S. 371 (Supreme Court, 2005)
Giuseppe Spina v. Department of Homeland Security
470 F.3d 116 (Second Circuit, 2006)
Star Athletica, L. L. C. v. Varsity Brands, Inc.
580 U.S. 405 (Supreme Court, 2017)
Epic Systems Corp. v. Lewis
584 U.S. 497 (Supreme Court, 2018)
United States v. Zullo
976 F.3d 228 (Second Circuit, 2020)
United States v. Dwight Jackson
991 F.3d 851 (Seventh Circuit, 2021)
United States v. Darrel King
24 F.4th 1226 (Ninth Circuit, 2022)
United States v. Marlon Clenista
26 F.4th 566 (Second Circuit, 2022)
Grajales v. Commissioner of Internal Revenue
47 F.4th 58 (Second Circuit, 2022)
United States v. Epskamp
832 F.3d 154 (Second Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
143 F.4th 119, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-coonan-ca2-2025.