United States v. Simmons

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 26, 2025
Docket23-6771
StatusUnpublished

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

Opinion

23-6771 United States v. Simmons

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 26th day of February, two thousand twenty-five.

PRESENT:

RICHARD J. SULLIVAN, ALISON J. NATHAN, MARIA ARAÚJO KAHN, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. No. 23-6771

STEPHEN SIMMONS,

Defendant-Appellant. _____________________________________ For Defendant-Appellant: SARAH BAUMGARTEL, Assistant Federal Defender, Federal Defenders of New York, New York, NY.

For Appellee: COURTNEY HEAVEY (Jamie Bagliebter, Nathan Rehn, on the brief), Assistant United States Attorneys, for Matthew Podolsky, Acting United States Attorney for the Southern District of New York, New York, NY.

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

District of New York (Valerie E. Caproni, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the July 12, 2023 judgment of the district court

is AFFIRMED.

Stephen Simmons appeals from a judgment of conviction following a jury

trial in which he was found guilty of possessing ammunition as a felon under 18

U.S.C. § 922(g)(1) during the course of a shooting in the Bronx. Although the

shooting did not constitute an element of the count of conviction, the district court

concluded that the shooting constituted attempted murder and thus applied the

Sentencing Guideline for attempted murder before sentencing Simmons to 120

months’ incarceration. On appeal, Simmons challenges both his conviction under

section 922(g)(1) and his sentence under the attempted murder Guideline. We

2 assume the parties’ familiarity with the underlying facts, procedural history, and

issues on appeal.

I. Jury Instructions

Simmons raises two challenges to the jury instructions, neither of which he

preserved below. When a challenge to a jury instruction was raised before the

district court, we review the instruction de novo. See United States v. Rommy, 506

F.3d 108, 118 (2d Cir. 2007). But when the challenge was not preserved, we

review it only for plain error. See Fed. R. Crim. P. 52(b). We will correct such an

error only when it is “clear and obvious, affected the defendant[’s] substantial

rights, and seriously affected the fairness, integrity, or public reputation of the

judicial proceedings.” United States v. Mehta, 919 F.3d 175, 180 (2d Cir. 2019). To

be clear or obvious, an error must be “clear under current law,” which generally

requires “binding precedent from the Supreme Court or this Court” that dictates

a different conclusion. United States v. Whab, 355 F.3d 155, 158 (2d Cir. 2004). In

order to show that the error affected his “substantial rights,” the defendant has the

burden of establishing a “reasonable probability that the error affected the

outcome of the trial.” United States v. Groysman, 766 F.3d 147, 155 (2d Cir. 2014)

(internal quotation marks omitted).

3 A. Jury Instruction Regarding Immunized Witness Testimony

Simmons first argues that the district court plainly erred in giving a charge

that “did not instruct the jury to scrutinize immunized witness testimony with

care.” Simmons Br. at 29. At trial, the government relied heavily on testimony

by Jonas Bolden – the shooting victim – and his associate Joe Holloway, each of

whom testified that Simmons had followed Bolden into an elevator and shot him

at close range while Holloway looked on. Because their testimony revealed that

they were involved in drug trafficking, both Bolden and Holloway testified

pursuant to immunity agreements. The government thus proposed an

immunized witness charge – “[a]dapted” from a model jury instruction – that the

district court largely adopted without objection from Simmons. App’x at 900–02

(citing Sand, Modern Federal Jury Instructions - Criminal, Instr. 7–8 (2023)). As

delivered, the instruction explained that “[t]wo witnesses testified under a grant

of immunity” and directed the jury to consider “whether the fact that the

witness[es] w[ere] immunized ha[d] intentionally or otherwise colored or

distorted [their] testimony.” App’x at 849.

Simmons argues that this charge was incorrect because – unlike the model

instruction – it did not direct the jury to “examine[]” the testimony of an

4 immunized witness with “greater care than the testimony of an ordinary witness”

or to “scrutinize [the testimony] closely.” Simmons Br. at 19–20. But we cannot

agree that this was plain error, for the simple reason that no “binding precedent”

has found error where a district court failed to instruct the jury that it must use

greater scrutiny when inspecting the testimony of an immunized victim. Whab,

355 F.3d at 158. In fact, we have never imposed that level of scrutiny on testimony

by cooperating witnesses, who may have an even greater “interest in currying favor

with the prosecutor” than immunized victims. United States v. Vaughn, 430 F.3d

518, 524 (2d Cir. 2005) (requiring only that district courts “identify” for the jury

any “possible motivations” that a cooperating witness may have and stating that

courts need not “over-emphasize the obvious [fact]” that cooperators are biased).

Because Simmons lacks binding precedent to support his claim of error, he cannot

demonstrate plain error here. 1

1 We also reject Simmons’s argument that the government “misled” the jury about the scope of

Bolden’s and Holloway’s immunity. Simmons Br. at 33. The agreements gave Bolden and Holloway immunity from prosecution based on any evidence that directly or indirectly derived from their testimony. See App’x at 903–06. But both could still be prosecuted with evidence obtained through wholly independent means, as the government argued to the jury. Id. at 827; see also United States v. Allen, 864 F.3d 63, 91–92 (2d Cir. 2017).

5 B. Limiting Instruction Regarding Prior Felony Conviction

Simmons next asserts that the district court should have given a limiting

instruction concerning Simmons’s prior felony conviction. But while Simmons

requested that instruction in his pretrial briefing, he never asked for one at trial.

His argument on appeal is thus subject to plain error review. See United States v.

Crowley, 318 F.3d 401, 413 (2d Cir.

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United States v. Rommy
506 F.3d 108 (Second Circuit, 2007)
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United States v. Frederick Schultz
333 F.3d 393 (Second Circuit, 2003)
United States v. Usama Sadik Ahmed Abdel Whab
355 F.3d 155 (Second Circuit, 2004)
United States v. Grinage
390 F.3d 746 (Second Circuit, 2004)
United States v. Derek A. Vaughn, Zaza Leslie Lindo
430 F.3d 518 (Second Circuit, 2005)
United States v. Osama Awadallah
436 F.3d 125 (Second Circuit, 2006)
United States v. Contorinis
692 F.3d 136 (Second Circuit, 2012)
United States v. Stroman
498 F. App'x 67 (Second Circuit, 2012)
United States v. Bogle
717 F.3d 281 (Second Circuit, 2013)
United States v. Kelley
551 F.3d 171 (Second Circuit, 2009)
United States v. Groysman
766 F.3d 147 (Second Circuit, 2014)
United States v. Allen
864 F.3d 63 (Second Circuit, 2017)
United States v. Mehta
919 F.3d 175 (Second Circuit, 2019)

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