United States v. Murphy

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 7, 2025
Docket24-404-cr
StatusUnpublished

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

Opinion

24-404-cr United States v. Murphy

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 7th day of February, two thousand twenty-five.

Present: SUSAN L. CARNEY, MICHAEL H. PARK, WILLIAM J. NARDINI, Circuit Judges.

__________________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 24-404-cr

SHERROD MURPHY,

Defendant-Appellant. *

FOR APPELLEE: Justin Horton and Danielle R. Sassoon, Assistant United States Attorneys, for Damian Williams, United States Attorney for the Southern District of New York, New York, NY.

FOR DEFENDANT-APPELLANT: Nicholas Pinto, New York, NY.

* The Clerk of Court is respectfully directed to amend the caption accordingly. Appeal from a judgment of the United States District Court for the Southern District of

New York (Cote, J.).

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

DECREED that the judgment of the district court is AFFIRMED.

On October 10, 2023, Defendant-Appellant Sherrod Murphy pleaded guilty to one count

of unlawfully possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). The

government charged Murphy after finding a handgun in his motel room while arresting him for

suspected mail theft. Murphy’s plea agreement stipulated to his mail-theft offenses, parole

violation, and a Sentencing Guidelines offense level of 17. App’x at 15-19. On February 6,

2024, the district court calculated a Sentencing Guidelines range of 51 to 63 months’

imprisonment. The district court then imposed an above-Guidelines sentence of 72 months’

imprisonment “as a matter of general deterrence and appropriate punishment” in light of Murphy’s

“serious, longstanding, [and] violent” criminal history and “significant” mail-theft conduct.

App’x at 57. Murphy appeals, arguing that his sentence is both procedurally and substantively

unreasonable. We assume the parties’ familiarity with the underlying facts, procedural history

of the case, and issues on appeal.

I. Procedural Reasonableness

“A district court commits procedural error where it fails to calculate the Guidelines

range[,] . . . makes a mistake in its Guidelines calculation, . . . treats the Guidelines as

mandatory[,] . . . does not consider the § 3553(a) factors, . . . rests its sentence on a clearly

erroneous finding of fact[,]” or “fails adequately to explain its chosen sentence” with “an

explanation for any deviation from the Guidelines range.” United States v. Cavera, 550 F.3d

2 180, 190 (2d Cir. 2008) (en banc). We apply a “rigorous plain error” standard of review when a

defendant did not raise his claim of procedural error before the district court. United States v.

Villafuerte, 502 F.3d 204, 208 (2d Cir. 2007). To show plain error, a defendant must establish

that “(1) there is an error; (2) the error is clear or obvious, rather than subject to reasonable dispute;

(3) the error affected the appellant’s substantial rights, which in the ordinary case means it affected

the outcome of the district court proceedings; and (4) the error seriously affects the fairness,

integrity or public reputation of judicial proceedings.” United States v. Marcus, 560 U.S. 258,

262 (2010) (cleaned up).

Murphy argues that the district court’s sentence is procedurally unreasonable because it

(1) did not adequately explain its upward variance and (2) failed to consider his mitigating

circumstances under 18 U.S.C. § 3553(a). Murphy did not make these arguments in the district

court, so we review for plain error and find none.

First, Murphy contends that the district court erred in varying upward based on his criminal

history and serious conduct because “these factors were already taken into consideration in the

guidelines.” But the district court may “impose[] a non-Guidelines sentence based upon

section 3553(a) factors already accounted for in the Guidelines range” as long as it adequately

explains its reasons for imposing that sentence. United States v. Sindima, 488 F.3d 81, 87 (2d

Cir. 2007); see also United States v. Ryan, No. 21-1951, 2022 WL 16842930, at *3 (2d Cir. Nov.

10, 2022) (summary order) (“[T]he district court adequately explained why [the defendant’s]

reckless conduct was different from an ordinary case covered by the Guidelines enhancement and

did not procedurally err in relying on that same conduct in imposing a sentence above the

Guidelines range.”).

3 The district court offered such an explanation here. It stated that Murphy deserved an

upward variance because of his “serious, longstanding, [and] violent” criminal history. App’x at

57. As a matter of specific deterrence, it imposed a more significant sentence “to send a message”

to Murphy that he “must choose a different path and give up crime, give up weapons, [and] no

longer engage in thievery,” because prior prison terms had failed to dissuade him from offending.

Id. The district court explained that its sentence was warranted for purposes of “general

deterrence” as well. Id. Such “deterrence-based rationale[s] easily suffice[] to justify” an

above-Guidelines sentence. Cavera, 550 F.3d at 197. The district court also explained that the

“scale of [Murphy’s] mail theft scheme” warranted a “significant sentence” as a matter of

“appropriate punishment.” App’x at 57. The district court thus “provided an adequate

explanation of its rationale for the upward variance” based on its context-specific view of the

severity of Murphy’s criminal history and conduct. United States v. Sealed Defendant One, 49

F.4th 690, 697 (2d Cir. 2022).

Second, Murphy argues that the district court’s Section 3553(a) analysis was procedurally

unreasonable because it “failed to adequately consider [his] upbringing and particularly harsh

treatment in jail.” We disagree. “[W]e never have required a District Court to make specific

responses to points argued by counsel in connection with sentencing.” United States v. Bonilla,

618 F.3d 102, 111 (2d Cir. 2010). The district court “must satisfy us only that it has considered

the party’s arguments and has articulated a reasonable basis for exercising its decision-making

authority.” Id. “We presume that a sentencing judge has faithfully discharged her duty to

consider the statutory factors and we do not require robotic incantations that the district court has

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Related

United States v. Fernandez
443 F.3d 19 (Second Circuit, 2006)
United States v. Bonilla
618 F.3d 102 (Second Circuit, 2010)
United States v. Felix Sindima
488 F.3d 81 (Second Circuit, 2007)
United States v. Broxmeyer
699 F.3d 265 (Second Circuit, 2012)
United States v. Villafuerte
502 F.3d 204 (Second Circuit, 2007)
United States v. Irving
554 F.3d 64 (Second Circuit, 2009)
United States v. Muzio
966 F.3d 61 (Second Circuit, 2020)
United States v. Zhong
26 F.4th 536 (Second Circuit, 2022)
United States v. Marcus
176 L. Ed. 2d 1012 (Supreme Court, 2010)
United States v. Sealed One
49 F.4th 690 (Second Circuit, 2022)

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United States v. Murphy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-murphy-ca2-2025.