United States v. Darrah

132 F.4th 643
CourtCourt of Appeals for the Second Circuit
DecidedMarch 28, 2025
Docket23-7001-cr
StatusPublished
Cited by2 cases

This text of 132 F.4th 643 (United States v. Darrah) 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. Darrah, 132 F.4th 643 (2d Cir. 2025).

Opinion

23-7001-cr United States v. Darrah

1 United States Court of Appeals 2 for the Second Circuit 3 4 AUGUST TERM 2024 5 No. 23-7001-cr 6 7 8 UNITED STATES OF AMERICA, 9 Appellee, 10 11 v. 12 13 KENNETH DARRAH, 14 Defendant-Appellant. 15 16 17 SUBMITTED: OCTOBER 15, 2024 18 DECIDED: MARCH 28, 2025 19 20 21 Before: WALKER, JACOBS, and MERRIAM, Circuit Judges. 22 23 Kenneth Darrah appeals from a judgment of the United States 24 District Court for the Northern District of New York (Suddaby, J.), 25 entered on August 23, 2023, convicting him, following a guilty plea, 26 of distribution of child pornography in violation of 18 U.S.C 27 §2252A(a)(2)(A), and sentencing him principally to a prison term of 28 106 months, to be followed by a 20-year term of supervised release. 29 For the reasons that follow, we affirm the district court’s judgment as 30 to its application of the five-level Guidelines increase for distribution 31 of child pornography under the newly-amended U.S.S.G. 32 §2G2.2(b)(3)(B) and (ii) as harmless error, vacate the judgment insofar 33 as it impermissibly delegates judicial authority to the Probation Office 1 to determine how many internet-capable devices Darrah may possess 2 upon supervised release, and remand for resentencing consistent 3 with this opinion.

4 AFFIRMED in part and VACATED and REMANDED in 5 part. 6 7 JAMES P. EGAN, Assistant 8 Federal Public Defender, 9 Syracuse, NY, for Defendant- 10 Appellant. 11 12 13 RAJIT S. DOSANJH, Assistant 14 United States Attorney, for 15 Carla B. Freedman, United 16 States Attorney for the 17 Northern District of New York, 18 for the United States of America.

2 1 DENNIS JACOBS, Circuit Judge:

2 Kenneth Darrah exchanged messages for two months with an 3 undercover law enforcement officer, or Online Covert Employee 4 (“OCE”), who was posing as the mother of a nine-year-old girl. The 5 generally revolting particulars can be elided. What matters is that, in 6 expectation of receipt of a picture of the child, Darrah transmitted to 7 the OCE an audiovisual file of child pornography through the Kik 8 Messenger application. He pled guilty to a one-count indictment, 9 charging distribution of child pornography in violation of 18 U.S.C. 10 §2252A(a)(2)(A); and he was sentenced by the United States District 11 Court for the Northern District of New York (Suddaby, J.), as relevant 12 here, to 106 months’ imprisonment and 20 years’ supervised release.

13 On appeal, Darrah challenges: (i) the procedural 14 reasonableness of a five-level increase for distribution of child 15 pornography in exchange for valuable consideration under U.S.S.G. 16 §2G2.2(b)(3)(B); (ii) the substantive reasonableness of the 106-month 17 sentence; and (iii) the imposition of a special condition of supervised 18 release limiting him to possession of a single internet-capable device 19 upon release.

20 First, we conclude that it was error to apply the five-level 21 increase for distribution of child pornography when there was no 22 evidence of an agreement to exchange anything of value as required 23 under the amended version of U.S.S.G. §2G2.2(b)(3)(B). However, the 24 district court’s error was harmless. Next, we conclude that the below- 25 Guidelines 106-month sentence was substantively reasonable. 26 Finally, we conclude that the district court erred in delegating judicial 27 authority to the Probation Office to determine how many internet- 28 capable devices Darrah could possess upon supervised release.

29 Accordingly, we affirm the judgment as to the term of 30 imprisonment; but we vacate the judgment as to its impermissible 31 delegation of judicial authority and remand for resentencing 32 consistent with this opinion.

3 1 BACKGROUND

2 Darrah’s Presentence Investigation Report (“PSR”) reflected a 3 base offense level of 22. The offense level was increased, inter alia, by 4 five levels because the district court determined that the child 5 pornography was distributed for valuable consideration. See U.S.S.G. 6 §2G2.2(b)(3)(B). The Probation Office determined that Darrah’s total 7 adjusted offense level was 34. Based on Darrah’s adjusted offense 8 level and criminal history category of I, Darrah’s Guidelines range 9 was 151 to 188 months. Darrah objected to the five-level increase.

10 At Darrah’s sentencing hearing, the district court likewise 11 calculated a total offense level of 34 and a criminal history category of 12 I, with a total Guidelines range of 151 to 188 months. The district court 13 imposed a below-Guidelines term of 106 months’ imprisonment and 14 recommended that Darrah participate in sex offender treatment while 15 in the custody of the Bureau of Prisons. In support of its sentence, the 16 district court referenced the nature of Darrah’s communications, in 17 which he sought explicit images and videos of a nine-year-old girl, 18 provided the OCE instructions on how to pose her, and expressed 19 interest in meeting her. The court also considered that Darrah had a 20 single prior criminal conviction, that he had no known history of 21 sexual contact with minors, and that the instant offense involved the 22 distribution of a single child pornography video. The court reinforced 23 the sentence imposed:

24 [R]egardless of any errors that may have been argued 25 with regard to defense counsel and the guideline scoring, 26 the Court would have imposed this sentence as it is 27 sufficient but not greater than necessary to meet the goals 28 of sentencing outlined in 18 USC Section 3553(a). Had the 29 guideline range not been affected by the five-level 30 enhancement, this sentence would have been still not 31 outside of that guideline range, but below. 32

4 1 App’x at 99.

2 The district court also imposed a 20-year term of supervised 3 release and ordered Darrah to comply with 13 special conditions of 4 supervised release recommended by the Probation Office. Among 5 those, Special Condition 8, a limitation on internet capable devices, as 6 recommended in the PSR, provided that upon release Darrah could 7 not possess an internet-capable device until he participated in the 8 Internet and Computer Management Program (ICMP); the 9 recommended condition did not limit how many devices Darrah 10 could then possess once he successfully completed the ICMP. At 11 sentencing, the district court imposed an additional internet 12 restriction, limiting Darrah to a single internet-capable device upon 13 release and completion of the ICMP. The district court premised this 14 limitation on Darrah’s “poor impulse control.” App’x at 103. The 15 district court further explained that the restriction was necessary “to 16 promote the defendant’s rehabilitation and protect the public from 17 further crimes of this defendant.” Id.

18 Defense counsel asked the district court to confirm that it was 19 limiting Darrah to one internet-capable device as a condition of 20 supervised release. The court explained:

21 Initially, yes, as part of that special condition for 22 supervised release, unless and until probation feels like 23 they can monitor his use beyond that and there aren’t 24 any problems. That can be adjusted, but initially the 25 special condition calls for only one internet-capable 26 device, which will be in the probation’s monitoring 27 program. 28 29 App’x at 105-06.

30 The written judgment contained the 13 special conditions 31 recommended in the PSR, but Special Condition 8 of the written 32 judgment omitted the limitation dictated at sentencing that Darrah

5 1 would be restricted to a single internet-capable device.

2 DISCUSSION

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132 F.4th 643, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-darrah-ca2-2025.