United States v. Gnahore

CourtCourt of Appeals for the Second Circuit
DecidedApril 17, 2026
Docket23-6327 (L)
StatusUnpublished

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

Opinion

23-6327 (L) United States v. Gnahore

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 TO 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 17th day of April, two thousand twenty-six.

PRESENT:

ROBERT D. SACK, DENNY CHIN, RICHARD J. SULLIVAN, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. Nos. 23-6327 (Lead), 23-6359 (Con) SALIFOU CONDE, SEKHOU TOURE, ALSENY KEITA, ABRAHIM DUKURAY, ABOUBAKAR BAKAYOKO, ISSIAGA SYLLA, Defendants,

SYLVAIN GNALI GNAHORE, FALIKOU KONE,

Defendants-Appellants. _____________________________________

For Defendant-Appellant Michelle Anderson Barth, Law Office of Sylvain Gnali Gnahore: Michelle Anderson Barth, Burlington, VT.

For Defendant-Appellant Falikou Kone, pro se, Cresson, PA. Falikou Kone:

For Appellee: Kevin Grossinger, James Ligtenberg, Assistant United States Attorneys, for Jay Clayton, United States Attorney for the Southern District of New York, New York, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Valerie E. Caproni, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the March 17, 2023 and April 4, 2023

judgments of the district court are AFFIRMED.

Sylvain Gnali Gnahore appeals from a judgment of conviction following his

plea of guilty to bank fraud, in violation of 18 U.S.C. §§ 1344 and 2 (Count Two).

Falikou Kone appeals from a judgment following a jury trial in which he was

convicted of (1) wire fraud, in violation of 18 U.S.C. §§ 1343 and 2 (Count Two);

2 (2) bank fraud, in violation of 18 U.S.C. §§ 1344 and 2 (Count Three); and

(3) transporting stolen vehicles, in violation of 18 U.S.C. §§ 2312 and 2 (Count

Four). Gnahore’s and Kone’s respective convictions stemmed from their

participation in a scheme to defraud banks using fake aliases and false checks (the

“Check Fraud Scheme”), and a scheme to steal cars from rental car companies (the

“Stolen Car Scheme”).

In this consolidated appeal, Gnahore contends that his counsel was

constitutionally ineffective by stipulating in his plea agreement to a Sentencing

Guidelines calculation based on intended (rather than actual) loss. See U.S.S.G.

§ 2B1.1. Meanwhile, Kone, proceeding pro se, raises a plethora of jurisdictional,

evidentiary, constitutional, and sentencing challenges to his conviction. We

assume the parties’ familiarity with the underlying facts, procedural history, and

issues on appeal, to which we refer only as necessary to explain our decision.

I. Gnahore’s Counsel Was Not Constitutionally Ineffective. 1

Gnahore’s sole argument on appeal is that his trial counsel provided

ineffective assistance of counsel when he stipulated in the plea agreement to a

1 Although it is “preferable” for ineffective-assistance claims to be brought under a motion pursuant to 28 U.S.C. § 2255, we may review such claims on direct appeal where, as here, “the factual record is fully developed and resolution of the Sixth Amendment claim on direct appeal is beyond any doubt or in the interest of justice.” United States v. Gaskin, 364 F.3d 438, 468 (2d

3 Guidelines calculation predicated on “intended loss.” Gnahore Br. at 16; see

U.S.S.G. § 2B1.1(b)(1); Strickland v. Washington, 466 U.S. 668, 688 (1984). But as

Gnahore concedes in his Rule 28(j) letter, this argument is foreclosed by our

decision in United States v. Rainford, 110 F.4th 455 (2d Cir. 2024). There, we held

that “the application note defining loss [to include intended loss] is neither

inconsistent with nor a plainly erroneous reading of the [G]uideline,” and thus

remains “‘authoritative.’” Id. at 475 (quoting Stinson v. United States, 508 U.S. 36,

38 (1993)). Because the “failure to make a meritless argument does not rise to the

level of ineffective assistance,” United States v. Kirsh, 54 F.3d 1062, 1071 (2d Cir.

1995), we conclude that Gnahore’s counsel was not constitutionally deficient.

II. Kone’s Challenges to His Conviction Are Without Merit.

Unlike Gnahore, whose brief is focused on a sole appellate issue, Kone raises

a host of arguments, including that: (1) the indictment was insufficiently specific,

depriving the district court of jurisdiction; (2) his transportation-of-stolen-motor-

vehicles count was improperly joined in the indictment; (3) the wire-fraud and

bank-fraud counts should have been dismissed for retroactive misjoinder; (4) the

district court erred by denying his motions to suppress evidence; (5) the district

Cir. 2004) (internal quotation marks omitted).

4 court erred by denying his motion for a subpoena pursuant to Federal Rule of

Criminal Procedure 17(c); (6) the government committed general misconduct;

(7) his sentence was procedurally and substantively unreasonable; and (8) his

counsel was constitutionally ineffective. Although “[w]e liberally construe

pleadings and briefs submitted by pro se litigants, reading such submissions to

raise the strongest arguments they suggest,” Kone’s arguments are plainly

meritless. McLeod v. Jewish Guild for the Blind, 864 F.3d 154, 156 (2d Cir. 2017)

(alteration rejected and internal quotation marks omitted).

A. Subject-Matter Jurisdiction.

Kone first contends that the district court lacked subject-matter jurisdiction

because “all three counts of conviction[]” charged in the fourth superseding

indictment – wire fraud (Count Two), bank fraud (Count Three), and

transportation of stolen motor vehicles (Count Four) – failed to “specif[y] . . . the

elements of the crime[s]” or the locations in which they were committed. Kone

Br. at 5. We disagree.

We review denials of motions to dismiss an indictment de novo.

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