United States v. Patterson

CourtCourt of Appeals for the Second Circuit
DecidedJune 3, 2025
Docket24-1590-cr
StatusUnpublished

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

Opinion

24-1590-cr U.S. v. Patterson

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 3rd day of June, two thousand twenty-five.

Present:

EUNICE C. LEE, SARAH A.L. MERRIAM, MARIA ARAÚJO KAHN, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. No. 24-1590-cr

GLEN PATTERSON,

Defendant-Appellant. _____________________________________

For Appellee: Benjamin Levander, Stephanie Simon, Assistant United States Attorneys, for Danielle R. Sassoon, United States Attorney for the Southern District of New York, New York, NY. For Defendant-Appellant: Darrell Fields, Assistant Federal Defender, Federal Defenders of New York, Inc., Appeals Bureau, New York, NY.

Appeal from a June 4, 2024 judgment of revocation entered in the United States District

Court for the Southern District of New York (Seibel, J.).

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

DECREED that the judgment of the district court is AFFIRMED.

Defendant-Appellant Glen Patterson appeals from a judgment revoking his ten-year term

of supervised release and sentencing him to eight months’ imprisonment, followed by a new term

of ten years of supervised release. Patterson’s initial term of supervised release began in October

2016 after service of a custodial sentence of thirty-six months’ imprisonment following his

conviction for receipt and distribution of child pornography, in violation of 18 U.S.C. §§

2252A(a)(2) and (b)(1). Under the terms of his supervised release, Patterson was prohibited

from, among other things, having “deliberate contact with any child under 18 years of age, unless

approved by the probation department” (the “no-contact condition”). App’x at 50.

On February 8, 2024, the United States Probation Office filed a violation report with one

specification. The violation report alleged that in or around May 2023, Patterson violated the no-

contact condition, committing a Grade C violation of supervised release by using Omegle, a web-

based chat service, to deliberately seek out children between the ages of 12 and 16 to engage in

chats that were sexual in nature. For this violation, the Sentencing Guidelines policy statement

recommended a range of three to nine months’ imprisonment, with a statutory maximum of two

years’ imprisonment and a life term of supervised release.

2 On March 8, 2024, Patterson appeared before the district court and admitted to the sole

specification in the violation report. Sentencing was held on May 31, 2024. At sentencing, the

government recommended a sentence of twelve months’ imprisonment followed by ten years of

supervised release. In response, defense counsel requested a non-custodial sentence with ten

years of supervised release. Ultimately, the district court revoked Patterson’s supervised release

and imposed a sentence of eight months’ imprisonment, to be followed by a new term of ten years

of supervised release.

We assume the parties’ familiarity with the remaining underlying facts, the procedural

history, and the issues on appeal, to which we refer only as necessary to explain our decision.

* * *

“All federal sentences, including those imposed for violations of supervised release, are

reviewed for reasonableness.” United States v. Gonzalez, 529 F.3d 94, 97 (2d Cir. 2008). “Our

review of criminal sentences includes both procedural and substantive components,” United States

v. McIntosh, 753 F.3d 388, 393–94 (2d Cir. 2014), using “a deferential abuse-of-discretion

standard,” United States v. Cavera, 550 F.3d 180, 189 (2d Cir. 2008) (en banc) (internal quotation

marks omitted). “The procedural inquiry focuses primarily on the sentencing court’s compliance

with its statutory obligation to consider the factors detailed in 18 U.S.C. § 3553(a), while the

substantive inquiry assesses the length of the sentence imposed in light of the § 3553(a) factors.”

United States v. Castillo, 896 F.3d 141, 148 (2d Cir. 2018) (quoting United States v. Verkhoglyad,

516 F.3d 122, 127 (2d Cir. 2008)). “As to substance, we will not substitute our own judgment

for the district court’s on the question of what is sufficient to meet the § 3553(a) considerations in

3 any particular case,” and we will “set aside a district court’s substantive determination only in

exceptional cases where the trial court’s decision cannot be located within the range of permissible

decisions.” Cavera, 550 F.3d at 189 (emphasis and internal quotation marks omitted).

On appeal, Patterson challenges the imposition of the new ten-year term of supervised

release as substantively unreasonable, contending that it is greater than necessary to serve the aims

of sentencing and supervision. Patterson raises three arguments for why the term of supervised

release is substantively unreasonable. First, Patterson argues that his sentence to eight months’

imprisonment alone served as significant punishment and adequate deterrence. Second, he

argues that the imposition of an additional ten years of supervision is “unnecessarily harsh”

because it would mean that he could spend a total of seventeen years under government supervision

despite not being a “hardened criminal.” Appellant’s Br. at 18. Last, Patterson argues that the

sentence is unreasonable since during his seven-year period of supervision prior to the violation

report, he remained productively employed, and there is no allegation that he was ever late to or

missed a session of his sex-offender therapy. We find Patterson’s arguments to be unpersuasive.

At sentencing, the district court explained that, upon consideration of the 18 U.S.C.

§ 3553(a) factors, as incorporated in 18 U.S.C. § 3583(e), the sentence imposed was based on the

court’s consideration of the nature and circumstances of the offense conduct itself, as well as the

other infractions Patterson committed while on supervision, Patterson’s history and characteristics,

the need for deterrence and to protect the public, and Patterson’s need for treatment. The

imposition of the ten-year term of supervised release here was not an abuse of discretion. The

4 nature and circumstances of the violation conduct involved Patterson deliberately seeking out and

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Related

United States v. Verkhoglyad
516 F.3d 122 (Second Circuit, 2008)
United States v. Wagner-Dano
679 F.3d 83 (Second Circuit, 2012)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Gonzalez
529 F.3d 94 (Second Circuit, 2008)
United States v. Castillo
896 F.3d 141 (Second Circuit, 2018)
United States v. McIntosh
753 F.3d 388 (Second Circuit, 2014)

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