United States v. Love

CourtCourt of Appeals for the Second Circuit
DecidedApril 8, 2025
Docket24-1706-cr
StatusUnpublished

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

Opinion

24-1706-cr United States v. Love

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 TO 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 8th day of April, two thousand twenty-five.

PRESENT: PIERRE N. LEVAL, JOSEPH F. BIANCO, WILLIAM J. NARDINI, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 24-1706-cr

THOMAS LOVE,

Defendant-Appellant. ∗ _____________________________________

FOR APPELLEE: Thomas R. Sutcliffe, Assistant United States Attorney, for Carla B. Freedman, United States Attorney for the Northern District of New York, Syracuse, New York.

∗ The Clerk of the Court is respectfully directed to amend the caption on this Court’s docket to be consistent with the caption on this order. FOR DEFENDANT-APPELLANT: Molly K. Corbett, Assistant Federal Public Defender, for Office of the Federal Public Defender, Albany, New York.

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

New York (Anne M. Nardacci, Judge).

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

DECREED that the judgment of the district court, entered on June 21, 2024, is AFFIRMED in

part and VACATED in part, and the case is REMANDED for further proceedings consistent with

this summary order.

Defendant-Appellant Thomas Love appeals from the district court’s judgment of

conviction following his guilty plea, pursuant to a plea agreement, to one count of receipt of child

pornography, in violation of 18 U.S.C. § 2252A(a)(2)(A). Following his guilty plea, the district

court sentenced Love principally to a term of 121 months’ imprisonment, to be followed by a 20-

year term of supervised release. On appeal, Love argues that his sentence was substantively

unreasonable and that the district court abused its discretion by imposing certain special conditions

of supervision, namely, (1) limiting him to the possession of a single internet-capable device, and

(2) requiring him to notify his employer of his conviction if the employment involves use of a

computer and to obtain approval for such employment from the United States Probation Office

(the “Probation Office”). 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.

I. Substantive Reasonableness

Love argues that his 121-month sentence, which was below his advisory range of 151 to

181 months under the United States Sentencing Guidelines (“Guidelines”), was substantively

unreasonable. In particular, Love asserts that, “[w]hile [he] received a sentence below the

2 [G]uidelines (albeit correctly calculated), that sentence was still unreasonable because the district

court gave no indication that it considered the [G]uidelines’ flaws.” Appellant’s Br. at 23. We

disagree.

We review a challenge to the substantive reasonableness of a sentence under a “deferential

abuse-of-discretion standard.” United States v. Cavera, 550 F.3d 180, 189 (2d Cir. 2008) (en banc)

(internal quotation marks and citation omitted). Under this deferential standard, “we do not

consider what weight we would ourselves have given a particular factor [at sentencing]. Rather,

we consider whether the factor, as explained by the district court, can bear the weight assigned it

under the totality of circumstances in the case.” Id. at 191 (internal citation omitted). A sentence

is therefore substantively unreasonable only if “affirming it would damage the administration of

justice because the sentence imposed was shockingly high, shockingly low, or otherwise

unsupportable as a matter of law.” United States v. Park, 758 F.3d 193, 200 (2d Cir. 2014) (per

curiam) (internal quotation marks and citation omitted). Moreover, we have emphasized that,

because in “the overwhelming majority of cases, a Guidelines sentence will fall comfortably within

the broad range of sentences that would be reasonable in the particular circumstances,” in most

circumstances, it is “difficult to find that a below-Guidelines sentence is unreasonabl[y severe].”

United States v. Perez-Frias, 636 F.3d 39, 43 (2d Cir. 2011) (per curiam) (internal quotation marks

and citation omitted).

Here, we discern no abuse of discretion in the district court’s imposition of the 121-month

sentence after its consideration of the factors set forth in 18 U.S.C. § 3553(a). In imposing the

sentence, the district court relied heavily on “the nature and circumstances of the offense” and the

seriousness of Love’s criminal conduct. App’x at 102; see 18 U.S.C. § 3553(a)(1)–(2)(A). For

example, the district court noted that the defendant possessed “over 300 images of child

3 pornography,” including images “portray[ing] sadistic conduct and other depictions of violence or

sexual abuse.” App’x at 102. The district court further emphasized that Love distributed at least

some of the child pornography he possessed. The district court thus determined that the 121-month

sentence “[was] sufficient, but not greater than necessary to meet the goals of sentencing outlined

in [Section 3553(a)].” Id. Given the seriousness of Love’s conduct and the danger that such

conduct poses to the public, we conclude that the Section 3553(a) factors upon which the district

court relied “can bear the weight assigned [them] under the totality of circumstances in the case,”

Cavera, 550 F.3d at 191, and the 121-month sentence was not “shockingly high . . . or otherwise

unsupportable as a matter of law,” Park, 758 F.3d at 200 (internal quotation marks and citation

omitted).

Love argues that the district court’s sentence is substantively unreasonable because the

court gave no indication that it considered the flaws in the application of Guidelines Section 2G2.2

governing child pornography offenses. We find this argument unpersuasive. To be sure, we have

cautioned that Section 2G2.2 “is fundamentally different from most and that, unless applied with

great care, [it] can lead to unreasonable sentences that are inconsistent with what § 3553 requires.”

United States v. Dorvee, 616 F.3d 174, 184 (2d Cir. 2010); accord United States v. Jenkins, 854

F.3d 181, 188 (2d Cir. 2017).

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

Related

United States v. Dorvee
616 F.3d 174 (Second Circuit, 2010)
United States v. Thomas
628 F.3d 64 (Second Circuit, 2010)
United States v. Perez-Frias
636 F.3d 39 (Second Circuit, 2011)
United States v. Aumais
656 F.3d 147 (Second Circuit, 2011)
United States v. Syed Ali Abrar
58 F.3d 43 (Second Circuit, 1995)
United States v. Duane Arthur Myers
426 F.3d 117 (Second Circuit, 2005)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Villafuerte
502 F.3d 204 (Second Circuit, 2007)
United States v. Dupes
513 F.3d 338 (Second Circuit, 2008)
United States v. Park
758 F.3d 193 (Second Circuit, 2014)
United States v. Joseph Vincent Jenkins
854 F.3d 181 (Second Circuit, 2017)
United States v. Dominique MacK
954 F.3d 551 (Second Circuit, 2020)
United States v. Rosa
957 F.3d 113 (Second Circuit, 2020)
United States v. Betts
886 F.3d 198 (Second Circuit, 2018)
United States v. Kunz
68 F.4th 748 (Second Circuit, 2023)
United States v. Davis
82 F.4th 190 (Second Circuit, 2023)

Cite This Page — Counsel Stack

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