United States v. Hernandez

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 22, 2025
Docket24-352
StatusUnpublished

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

Opinion

24-352-cr United States v. Hernandez

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 22nd day of January, two thousand twenty-five.

PRESENT: JOSÉ A. CABRANES, REENA RAGGI, MARIA ARAÚJO KAHN, Circuit Judges, __________________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 24-352-cr

JONATHAN HERNANDEZ, AKA Travieso, AKA Kraken,

Defendant-Appellant. ∗ ___________________________________________

∗ The Clerk of Court is respectfully directed to amend the official case caption as set forth above. FOR DEFENDANT-APPELLANT: MICHAEL K. BACHRACH, Law Office of Michael K. Bachrach, New York, NY.

FOR APPELLEE: JUSTINA L. GERACI (David C. James, on the brief), Assistant United States Attorneys, for Carolyn Pokorny, Acting United States Attorney for the Eastern District of New York, New York, NY.

Appeal from the February 1, 2024 judgment of the United States District Court for

the Eastern District of New York (Gary R. Brown, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment is AFFIRMED.

Defendant-Appellant Jonathan Hernandez (“Hernandez”) appeals from the

district court’s judgment of conviction following his guilty plea to one count of

racketeering, in violation of 18 U.S.C. § 1962(c). Hernandez contends that the government

breached his plea agreement and challenges the substantive reasonableness of his below-

Guidelines 520-month sentence. We assume the parties’ familiarity with the underlying

facts, the procedural history, and the issues on appeal, to which we refer only as necessary

to explain our decision to affirm.

DISCUSSION

I. Breach of Plea Agreement

Hernandez asserts that the government breached his plea agreement by seeking a

2 higher Guidelines calculation at sentencing than had been stipulated to in his plea

agreement. In particular, Hernandez faults the government for arguing in support of a

Probation-recommended two-level enhancement to his Guidelines offense level pursuant

to U.S.S.G. § 3A1.3. 1 He submits that because that enhancement was not accounted for in

the plea agreement’s Guidelines calculation, the government violated his reasonable

sentencing expectations. We are unconvinced.

In assessing Hernandez’s claim, “[w]e review [his] plea agreement in accordance

with principles of contract law and look to what the parties reasonably understood to be

the terms of the agreement.” United States v. Rivera, 115 F.4th 141, 146 (2d Cir. 2024)

(quoting United States v. Sealed Defendant One, 49 F.4th 690, 696 (2d Cir. 2022)). In doing

so, we look to “the precise terms of the plea agreement[] and to the parties’ behavior.” Id.

(quoting United States v. Helm, 58 F.4th 75, 83 (2d Cir. 2023)). Where, as here, a defendant

properly preserves his claim, “we review the argument that the [g]overnment breached

[the] plea agreement for harmless error.” United States v. Wilson, 920 F.3d 155, 162 (2d

Cir. 2019).

Here, we discern no breach of Hernandez’s plea agreement, which explicitly states

that “[t]he Guidelines estimate set forth in paragraph 2 is not binding on the [U.S.

1Section 3A1.3 provides that “[i]f a victim was physically restrained in the course of the offense,” the defendant’s offense level is “increase[d] by 2 levels.” It is undisputed that Oscar Acosta was physically restrained during his April 29, 2016 murder, to which Hernandez pleaded guilty. 3 Attorney’s] Office, the Probation Department or the Court.” App’x 143 (emphasis

added). Moreover, the plea agreement specifies that the government “will not be deemed

to have breached this agreement” if “the Guidelines offense level advocated by the Office,

or determined by the Probation Department or the Court, is, for any reason, including an

error in the estimate, different from the estimate.” Id.

Furthermore, the government’s sentencing submission and conduct at the

sentencing hearing are entirely consistent with the precise terms of the plea agreement.

The government argued for the application of the two-level restraint enhancement—

which was first identified and recommended by Probation in the Presentence Report

(“PSR”) dated October 17, 2022—admitting that its failure to include the adjustment in

the plea agreement was an “oversight,” App’x 191, and a “mistake,” Gov’t Br. at 18. 2

Indeed, at sentencing, the government emphasized that it could not “fact bargain” with

respect to the enhancement’s application, and that “the stipulated agreement on

guidelines in the plea agreement is nonbinding on the [g]overnment.” Id. at 199.

Ultimately, Hernandez “offers no persuasive explanation of how the plea agreement

could be breached by conduct it expressly permitted.” Sealed Defendant One, 49 F.4th at

696; see also United States v. Habbas, 527 F.3d 266, 270 (2d Cir. 2008) (identifying no breach

2 It is undisputed that relevant facts were known to the government at the time of sentencing on January 31, 2024, given that the government made an offer of proof at Hernandez’s May 31, 2022, change of plea hearing that MS-13 members “bound [Acosta’s] hands and feet.” App’x 171. Nonetheless, because the record does not indicate that the government acted in bad faith, we identify no gamesmanship. 4 when plea agreement “warned in several ways that the government was likely to

advocate for higher sentence” than estimated).

Even if we were to assume arguendo that the government’s conduct breached the

plea agreement, any error was harmless. Hernandez did not contest the applicability of

the enhancement, and the district court indicated that it had no choice but to apply it in

its independent calculation of the Guidelines. That suggests that the government’s

advocacy had no impact on the final Guidelines calculation. What’s more, the district

court clearly stated at sentencing that “even if the guidelines were to change, or if this

Court has erred in calculating those guidelines in some fashion, the sentence imposed

today would remain this Court’s considered determination.” App’x 214; see United States

v. Jass, 569 F.3d 47, 68 (2d Cir. 2009) (holding any Guidelines error harmless where district

court stated it would impose the same sentence based on independent assessment of

Section 3553(a) factors).

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

Related

United States v. Jass
569 F.3d 47 (Second Circuit, 2009)
United States v. Fernandez
443 F.3d 19 (Second Circuit, 2006)
United States v. Broxmeyer
699 F.3d 265 (Second Circuit, 2012)
United States v. Chu
714 F.3d 742 (Second Circuit, 2013)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Carr
557 F.3d 93 (Second Circuit, 2009)
United States v. Habbas
527 F.3d 266 (Second Circuit, 2008)
United States v. Pratheepan Thavaraja
740 F.3d 253 (Second Circuit, 2014)
United States v. Park
758 F.3d 193 (Second Circuit, 2014)
United States v. Mumuni
946 F.3d 97 (Second Circuit, 2019)
United States v. Portillo
981 F.3d 181 (Second Circuit, 2020)
United States v. Sealed One
49 F.4th 690 (Second Circuit, 2022)
United States v. Brown
843 F.3d 74 (Second Circuit, 2016)
United States v. Wilson
920 F.3d 155 (Second Circuit, 2019)
United States v. Helm
58 F.4th 75 (Second Circuit, 2023)
United States v. Davis
82 F.4th 190 (Second Circuit, 2023)
United States v. Gates
84 F.4th 496 (Second Circuit, 2023)
United States v. Moses
109 F. 4th 107 (Second Circuit, 2024)
United States v. Rivera
115 F.4th 141 (Second Circuit, 2024)

Cite This Page — Counsel Stack

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