United States v. London

CourtCourt of Appeals for the Second Circuit
DecidedApril 16, 2025
Docket24-817-cr
StatusUnpublished

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

Opinion

24-817-cr United States v. London

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 16th day of April, two thousand twenty-five.

PRESENT: JOSÉ A. CABRANES, RAYMOND J. LOHIER, JR., RICHARD J. SULLIVAN, Circuit Judges. ------------------------------------------------------------------ UNITED STATES OF AMERICA,

Appellee,

v. No. 24-817-cr

MAURICE LONDON,

Defendant-Appellant. ------------------------------------------------------------------ FOR DEFENDANT-APPELLANT: Marsha R. Taubenhaus, Law Offices of Marsha R. Taubenhaus, New York, NY

FOR APPELLEE: Monica J. Richards, Assistant United States Attorney, for Trini E. Ross, United States Attorney for the Western District of New York, Buffalo, NY

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

Western District of New York (John L. Sinatra, Jr., Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the District Court is AFFIRMED in part

and DISMISSED in part.

Maurice London appeals from a March 13, 2024 judgment of the United

States District Court for the Western District of New York (Sinatra, J.) sentencing

him principally to a term of 156 months’ imprisonment and five years’

supervised release following his guilty plea, pursuant to a plea agreement, to one

count of possession of 40 grams or more of fentanyl with intent to distribute, in

violation of 21 U.S.C. § 841(a)(1) and (b)(1)(B). London claims that the

Government deprived him of a fair sentencing when it advised the court, with no

prior notice to the defense, that the investigation into London arose from a fatal

2 overdose in which the fentanyl could be traced to London. He also challenges a

special condition of supervised release requiring that he contribute to the cost of

his drug treatment program. We assume the parties’ familiarity with the

underlying facts and the record of prior proceedings, to which we refer only as

necessary to explain our decision to affirm in part and dismiss in part.

We first address London’s argument that he was deprived of his right to a

fair sentencing by the Government’s representation at sentencing, without prior

notice, that the “genesis of th[e] investigation” leading to London’s arrest was the

2021 overdose death of an individual who had been in contact with a man who,

in turn, had obtained drugs from London. App’x 108. The Government asserted

that London “was ultimately not charged with the overdose death of the

individual, because there w[ere] a few things that the [Drug Enforcement

Administration] w[as] not able to confirm.” App’x 108. London contends that

the Government’s late disclosure breached the plea agreement, thereby vitiating

his appeal waiver, and that his sentence was procedurally unreasonable. He asks

that his sentence be vacated and that resentencing be assigned to a new judge. 1

1London also argues that he was “deprived of his right to the effective assistance of counsel” by the Government’s “failure to provide notice to the defense of its inflammatory allegation.” Appellant’s Br. 30. In view of our Court’s “baseline aversion

3 We construe plea agreements “according to contract law principles,

tempered with an awareness of due process concerns for fairness and adequacy

and construed strictly against the government.” United States v. Reyes-Arzate, 91

F.4th 616, 622 (2d Cir. 2024) (cleaned up). In considering whether the

Government has breached a plea agreement, “we look both to the precise terms

of the plea agreement[] and to the parties’ behavior” in order “to determine what

the reasonable understanding and expectations of the defendant were.” United

States v. Wilson, 920 F.3d 155, 163 (2d Cir. 2019) (cleaned up). London argues that

he “reasonably interpreted the government’s reservation of the right to present

additional facts as being limited to facts which were unknown to the government

when it prepared the agreement.” Appellant’s Br. 27. We are not persuaded.

The provisions of the plea agreement to which London points us preserve

the Government’s right to “provide to the Probation Office and the Court all the

information and evidence in its possession that the government deems relevant”

and to “modify its position with respect to any sentencing recommendation or

sentencing factor . . . in the event that . . . the government receives previously

to resolving ineffectiveness claims on direct appeal,” United States v. Willis, 14 F.4th 170, 187 n.6 (2d Cir. 2021) (quotation marks omitted), we exercise our discretion to “refrain from deciding it,” id. London is free to pursue this claim in a future petition under 28 U.S.C. § 2255. See United States v. Oladimeji, 463 F.3d 152, 154 (2d Cir. 2006). 4 unknown information.” App’x 26. The agreement does not impose an obligation

on the Government to disclose all the information and arguments on which it

intends to rely at sentencing, let alone disclose that material to London. In any

event, the Government did not use the challenged information to “press the

[District] Court for an enhanced offense level” over that which was already

contemplated in the plea agreement. United States v. Palladino, 347 F.3d 29, 34 (2d

Cir. 2003). The Government ultimately recommended a sentence within the

agreed Sentencing Guidelines range of 130-162 months, and London received a

sentence of 156 months’ imprisonment. App’x 103, 118. London’s claim that the

Government breached the plea agreement thus fails because he cannot show any

“Government[] deviation” from the plea agreement that “produce[d] serious

unfairness.” United States v. Helm, 58 F.4th 75, 84–85 (2d Cir. 2023) (quotation

marks omitted).

We also reject London’s argument that his sentence was procedurally

unreasonable. 2 Because London failed to object at sentencing, “rigorous plain

2 The parties dispute whether London’s five-year term of supervised release, which exceeds the range contemplated in the plea agreement’s appeal waiver provision, renders the waiver unenforceable in its entirety or whether the waiver may be enforced with respect to any challenge to London’s term of imprisonment, which did fall within the contemplated range. We need not resolve that dispute, however, because “[e]ven

5 error analysis is appropriate.” United States v.

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