United States v. Hollins

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 29, 2026
Docket25-350
StatusUnpublished

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

Opinion

25-350-cr (L) United States v. Hollins

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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held at the 2 Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3 29th day of January, two thousand twenty-six. 4 5 Present: 6 DEBRA ANN LIVINGSTON, 7 Chief Judge, 8 WILLIAM J. NARDINI, 9 MYRNA PÉREZ, 10 Circuit Judges. 11 _____________________________________ 12 13 UNITED STATES OF AMERICA, 14 15 Appellee, 16 17 v. 25-350 (L); 25-353 (Con) 18 19 ANDREW HOLLINS, AKA ANDREW JONES, 20 21 Defendant-Appellant. 22 _____________________________________ 23 24 For Appellee: ANDREW C. GILMAN, Eugenia A.P. Cowles, Assistant 25 U.S. Attorneys for Michael P. Drescher, Acting United 26 States Attorney, District of Vermont, Burlington, VT. 27 28 For Defendant-Appellant: BARCLAY T. JOHNSON, Assistant Federal Public 29 Defender for Michael L. Desautels, Federal Public 30 Defender, Burlington, VT. 31 32

1 1 Appeal from a judgment of the United States District Court for the District of Vermont

2 (Reiss, C.J.).

3 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

4 DECREED that the judgment of the district court is AFFIRMED.

5 Defendant-Appellant Andrew Hollins appeals from a final judgment entered by the United

6 States District Court for the District of Vermont on January 31, 2025, upon his guilty plea to one

7 count of distributing cocaine in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C); one count of

8 wire fraud, in violation of 18 U.S.C. § 1343; and one count of money laundering in violation of 18

9 U.S.C. § 1956(a)(1)(B)(i). Hollins was sentenced principally to 62 months’ imprisonment, to run

10 concurrently to any other sentence, as well as three years’ supervised release.

11 On appeal, Hollins argues that this federal sentence is procedurally and substantively

12 unreasonable by virtue of the district court’s failure to adjust his sentence to account for time he

13 spent in federal pretrial detention while serving a sentence imposed in New York State. We

14 disagree. In early 2023, Hollins was convicted of unrelated state firearms charges in New York

15 State and was sentenced in Kings County Supreme Court to an indeterminate sentence of two to

16 four years’ imprisonment. On May 16, 2023, pursuant to a writ of habeas corpus ad

17 prosequendum, Hollins was transferred from New York State custody to federal custody in the

18 District of Vermont to appear on the charges resulting in the present judgment. Repeatedly (at a

19 change of plea hearing, in connection with a motion to be returned to state custody, and again at

20 his sentencing) Hollins urged that he should be afforded consideration by the district court for his

21 time in federal pretrial detention in light of the alleged impact of this detention on the time he was

22 serving on his indeterminate New York State sentence. 1 At the January 31, 2025 sentencing

1 Pursuant to 18 U.S.C. § 3585(b), Hollins was not eligible for credit for time spent in federal pretrial

2 1 hearing, the district court sentenced Hollins to 62 months’ imprisonment, to run concurrently to

2 any other sentence, without either departing downward pursuant to the United States Sentencing

3 Guidelines or imposing a non-Guidelines sentence as Hollins urged. We assume the parties’

4 familiarity with the underlying facts, the procedural history of the case, and the issues on appeal,

5 which we reference only as necessary to explain our decision to AFFIRM.

6 A. Procedural Reasonableness

7 We review a procedural reasonableness challenge to a sentencing decision for abuse of

8 discretion. Gall v. United States, 552 U.S. 38, 56 (2007). “Procedural error occurs in situations

9 where, for instance, the district court miscalculates the Guidelines; treats them as mandatory; does

10 not adequately explain the sentence imposed; does not properly consider the § 3553(a) factors;

11 bases its sentence on clearly erroneous facts; or deviates from the Guidelines without explanation.”

12 United States v. Cossey, 632 F.3d 82, 86 (2d Cir. 2011). “A sentencing court’s legal application

13 of the Guidelines is reviewed de novo, while the court’s underlying factual findings with respect

14 to sentencing, established by a preponderance of the evidence, are reviewed for clear error.” Id.

15 (internal quotation marks omitted). We assume “that a sentencing judge has faithfully discharged

16 her duty to consider the statutory factors,” unless there is record evidence suggesting to the

17 contrary. United States v. Verkhoglyad, 516 F.3d 122, 129 (2d Cir. 2008) (internal quotation

18 marks omitted).

19 Hollins principally argues that the district court committed procedural error by declining

20 to rule on the issue of whether he should be afforded a reduction in his sentence for time spent in

21 federal pretrial detention while serving a sentence in New York State, thus failing to address his

custody from the Bureau of Prisons in the calculation of his federal sentence because he was receiving credit for this period toward his New York State sentence.

3 1 central claim that such a reduction “was appropriate because the federal prosecution meant that he

2 lost opportunities to be paroled from his New York State case starting on March 25, 2024.”

3 Appellant’s Br. at 28. We disagree.

4 First, the record amply establishes that the district court well understood it could impose a

5 lesser sentence to account for time spent in federal custody on the writ. Hollins moved to be

6 returned to New York State custody after entering his plea, precisely on the theory that absent his

7 return to state custody, he would lose the opportunity for parole. The district court, in denying

8 this motion, expressly noted that “[i]f the real issue is credit, sometimes the Court adjusts its

9 sentence to reflect lost credit, but it needs to make sense.” Joint App’x at 61. The court affirmed

10 that it would consider the question of a reduction at sentencing, but would find this argument most

11 persuasive if Hollins could show “that [he] would have been released on parole but for this federal

12 detainer, it would have happened a while ago, [he] would have been getting credit this whole time.”

13 Joint App’x at 72–73. The court warned that it was not promising any reduction on this theory—

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Related

United States v. Verkhoglyad
516 F.3d 122 (Second Circuit, 2008)
Rita v. United States
551 U.S. 338 (Supreme Court, 2007)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Cossey
632 F.3d 82 (Second Circuit, 2011)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Richardson
958 F.3d 151 (Second Circuit, 2020)

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