United States v. Hayes

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 9, 2026
Docket25-449
StatusUnpublished

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

Opinion

25-449 United States v. Hayes

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 9th day of February, two thousand twenty-six.

PRESENT: DENNIS JACOBS, PIERRE N. LEVAL, RICHARD J. SULLIVAN, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. No. 25-449

LERYCO HAYES, a.k.a. BIG BRO,

Defendant-Appellant. *

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

For Defendant-Appellant: Melissa A. Tuohey, Office of the Federal Public Defender, Syracuse, NY.

For Appellee: Rajit S. Dosanjh, Assistant United States Attorney, for John A. Sarcone III, United States Attorney for the Northern District of New York, Syracuse, NY.

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

District of New York (Mae A. D’Agostino, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the February 20, 2025 judgment of the district

court is AFFIRMED.

Leryco Hayes appeals from a judgment revoking his term of supervised

release and sentencing him to a term of imprisonment of 366 days followed by a

one-year term of supervised release after he violated the conditions of supervised

release imposed in connection with his prior conviction for possession with intent

to distribute cocaine, in violation of 21 U.S.C. § 841(a)(1). On appeal, Hayes

challenges the procedural reasonableness of his sentence, arguing principally that

the district court (1) relied on a clearly erroneous fact, and (2) failed to adequately

2 explain the reasons for imposing the revocation sentence. 2 We assume the parties’

familiarity with the underlying facts, procedural history, and issues on appeal.

To the extent that Hayes is challenging his term of incarceration, that

challenge is moot because he completed his prison sentence on or about August 1,

2025. “Article III . . . limits the federal judicial power to ‘cases’ and

‘controversies.’” United States v. Blackburn, 461 F.3d 259, 261 (2d Cir. 2006) (quoting

U.S. Const. art. III, § 2). This “case-or-controversy limitation . . . underpins both

our standing and our mootness jurisprudence.” Friends of the Earth, Inc. v. Laidlaw

Env't Servs. (TOC), Inc., 528 U.S. 167, 180 (2000). And a case is moot if it is

“impossible for the court to grant any effectual relief whatever to a prevailing

party.” Church of Scientology of Cal. v. United States, 506 U.S. 9, 12 (1992) (internal

quotation marks omitted). Because we cannot reduce a prison sentence that has

already been served, Hayes’s challenge to his term of imprisonment is moot.

By contrast Hayes’s attack on his twelve-month term of supervised release,

which he is currently serving, survives. We therefore must reach the merits of that

2 While Hayes gestures at challenging the substantive reasonableness of his sentence by contending that his revocation term of imprisonment and term of supervised relief were “too long under the totality of the circumstances,” Hayes Br. at 14, he provides no support for this assertion. Accordingly, we deem this challenge abandoned. See Debique v. Garland, 58 F.4th 676, 684 (2d Cir. 2023) (“We consider abandoned any claims not adequately presented in an appellant’s brief, and an appellant’s failure to make legal or factual arguments constitutes abandonment.” (internal quotation marks omitted)).

3 question, which we review for plain error because Hayes did not object when his

sentence was imposed. See United States v. Williams, 998 F.3d 538, 540 (2d Cir.

2021). “To establish plain error, the defendant must establish (1) error (2) that is

plain and (3) affects substantial rights.” United States v. Villafuerte, 502 F.3d 204,

209 (2d Cir. 2007). Under that standard, both of Hayes’s procedural challenges

fail.

First, Hayes contends that the district court erroneously stated that his “time

on supervision had been short-lived,” Hayes Br. at 15, when in fact he had

completed nearly three years of his original term of supervised release before that

term was revoked in 2023. But the record is clear that Hayes tested positive for

alcohol, marijuana, and cocaine within months of his release from prison in 2020,

and that he engaged in a host of other, more serious violations before that term of

supervised release was finally revoked in 2023. See App’x at 62–63. And after he

commenced his second term of supervised release in December 2023, Hayes again

violated the conditions of his supervision, this time a mere five months into his

new term. See id. at 91. Given this history, which the district court clearly

4 understood, we cannot say that the district court mischaracterized the record or

relied on a clearly erroneous fact when imposing its sentence.

Second, Hayes argues that the district court did not adequately explain the

reasons for the sentence it imposed. “In reviewing the procedural reasonableness

of a sentence,” we consider “whether the district court committed a significant

procedural error, such as failing to adequately explain the chosen sentence.”

United States v. Rosa, 957 F.3d 113, 117 (2d Cir. 2020) (internal quotation marks and

ellipsis omitted). But while a district court is required to “state in open court the

reasons for its imposition of the particular sentence,” 18 U.S.C. § 3553(c), we have

made clear that less specificity is required when sentencing for a violation of

supervised release than at a plenary sentencing, see United States v. Verkhoglyad,

516 F.3d 122, 133 (2d Cir. 2008).

Here, the district court explained that it considered Hayes’s violations to be

“serious,” and that Hayes had (1) a “criminal history Category [of] VI,”

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Related

United States v. Verkhoglyad
516 F.3d 122 (Second Circuit, 2008)
United States v. Wesley Blackburn
461 F.3d 259 (Second Circuit, 2006)
United States v. Villafuerte
502 F.3d 204 (Second Circuit, 2007)
United States v. Rosa
957 F.3d 113 (Second Circuit, 2020)
United States v. Joseph Williams
998 F.3d 538 (Second Circuit, 2021)
Debique v. Garland
58 F.4th 676 (Second Circuit, 2023)
Esteras v. United States
606 U.S. 185 (Supreme Court, 2025)

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