United States v. Hattersley

CourtCourt of Appeals for the Second Circuit
DecidedApril 15, 2025
Docket24-1700, 24-1701
StatusUnpublished

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

Opinion

24-1700, 24-1701 United States v. Hattersley

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 15th day of April, two thousand twenty-five.

PRESENT: RICHARD C. WESLEY, RICHARD J. SULLIVAN, MICHAEL H. PARK, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. Nos. 24-1700, 24-1701 DAVID HATTERSLEY,

Defendant-Appellant. *

* The Clerk of Court is respectfully directed to amend the official case caption as set forth above. _____________________________________

For Defendant-Appellant: Yuanchung Lee, Federal Defenders of New York, Inc., New York, NY.

For Appellee: Samuel P. Rothschild, James Ligtenberg, Assistant United States Attorneys, for Danielle R. Sassoon, 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 (Vernon S. Broderick, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the June 17, 2024 judgment of the district

court is AFFIRMED.

David Hattersley appeals from a judgment of conviction following his

guilty plea to four counts of bank robbery, in violation of 18 U.S.C. § 2113(a), and

three counts of Hobbs Act robbery, in violation of 18 U.S.C. § 1951(a), for which he

received a sentence of 108 months’ imprisonment to be followed by three years of

supervised release. On appeal, Hattersley challenges the procedural

reasonableness of his sentence. 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 to affirm.

2 We review the procedural reasonableness of a sentence for abuse of

discretion. See Gall v. United States, 552 U.S. 38, 51 (2007). A sentence is

procedurally unreasonable if the district court “fails to calculate (or improperly

calculates) the Sentencing Guidelines range, treats the Sentencing Guidelines as

mandatory, fails to consider the [18 U.S.C.] § 3553(a) factors, selects a sentence

based on clearly erroneous facts, or fails adequately to explain the chosen

sentence.” United States v. Chu, 714 F.3d 742, 746 (2d Cir. 2013) (internal quotation

marks omitted). Here, Hattersley contends that the district court erred in

calculating his offense level by classifying him as a “career offender” under section

4B1.1(a) of the United States Sentencing Guidelines based in part on a prior

conviction for attempted robbery in the third degree in violation of New York

Penal Law §§ 110 and 160.05. The only dispute is whether Hattersley’s conviction

for attempted third-degree robbery qualifies as a predicate “crime of violence”

under section 4B1.1(a).

At the time of Hattersley’s offense, section 4B1.2(a)(1) defined a “crime of

violence” as an offense that “has as an element the use, attempted use, or

threatened use of physical force against the person of another.” U.S.S.G.

§ 4B1.2(a)(1) (2018). Application Note 1 to the guideline provided that this

3 definition “include[s] the offenses of aiding and abetting, conspiring, and

attempting to commit such offenses.” Id. § 4B1.2 app. n. 1 (2018). Because

Hattersley concedes that completed third-degree robbery under New York law is

a crime of violence, the application note renders attempted third-degree robbery a

crime of violence as well. On appeal, Hattersley argues that Application Note 1’s

inclusion of “attempt” is plainly inconsistent with the guideline’s own definition

of “crime of violence” and not entitled to deference under either Stinson v. United

States, 508 U.S. 36, 45 (1993), or Kisor v. Wilkie, 588 U.S. 558, 573 (2019). As a result,

Hattersley maintains that his prior conviction for attempted third-degree robbery

is not a predicate “crime of violence” and that the district court’s application of the

career-offender guideline constituted procedural error. 1

We have previously upheld the authoritative nature of Application Note 1.

As we explained in United States v. Jackson, 60 F.3d 128, 131 (2d Cir. 1995),

Application Note 1 “interprets and explains [section] 4B1.2 by listing offenses that

constitute ‘controlled substance offenses’ and ‘crimes of violence.’” The note

1 The district court applied the 2023 version of the Guidelines, which now expressly incorporates

Application Note 1 into the main text of the career-offender guideline. Hattersley argues that the version in effect at the time of his offense, which did not include that language, rendered the career-offender guideline inapplicable. He therefore asserts that “the Ex Post Facto Clause requires the use of the earlier version.” Hattersley Br. at 18 (quoting United States v. Kilkenny, 493 F.3d 122, 127 (2d Cir. 2007)). Accordingly, that is the version we discuss.

4 simply “broadens the definition” of a controlled-substance offense and crime of

violence by providing that they also “include the offenses of aiding and abetting,

conspiring, and attempting to commit such offenses.” Id. (internal quotation

marks omitted). Since then, we have emphasized that Jackson “precludes any

further argument that Application Note 1 improperly conflicts with the [career-

offender] guideline text.” United States v. Richardson, 958 F.3d 151, 154 (2d Cir.

2020) (emphasis added) (internal quotation marks omitted); see also United States

v. Tabb, 949 F.3d 81, 87 (2d Cir. 2020) (noting that although some circuits have

found that “Application Note 1 conflicts with the text of [section] 4B1.2(b) by

including crimes that the Guideline text excludes,” we “are not at liberty to revisit

Jackson”).

Hattersley nevertheless contends that the Supreme Court’s subsequent

decision in United States v. Taylor, 596 U.S. 845 (2022), requires us to revisit these

prior precedents. But even if it could be argued that Taylor has effectively

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Related

United States v. Jass
569 F.3d 47 (Second Circuit, 2009)
Stinson v. United States
508 U.S. 36 (Supreme Court, 1993)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Jackson
60 F.3d 128 (Second Circuit, 1995)
United States v. Chu
714 F.3d 742 (Second Circuit, 2013)
United States v. Kilkenny
493 F.3d 122 (Second Circuit, 2007)
United States v. Cramer
777 F.3d 597 (Second Circuit, 2015)
Kisor v. Wilkie
588 U.S. 558 (Supreme Court, 2019)
United States v. Zimmian Tabb
949 F.3d 81 (Second Circuit, 2020)
United States v. Richardson
958 F.3d 151 (Second Circuit, 2020)
United States v. Taylor
596 U.S. 845 (Supreme Court, 2022)

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Bluebook (online)
United States v. Hattersley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-hattersley-ca2-2025.