United States v. Singh

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 22, 2026
Docket24-3261
StatusUnpublished

This text of United States v. Singh (United States v. Singh) 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. Singh, (2d Cir. 2026).

Opinion

24-3261-cr United States v. Singh

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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held at the 2 Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3 22nd day of January, two thousand twenty-six. 4 5 Present: 6 DEBRA ANN LIVINGSTON, 7 Chief Judge, 8 MYRNA PÉREZ, 9 MARIA ARAÚJO KAHN, 10 Circuit Judges, 11 _____________________________________ 12 13 UNITED STATES OF AMERICA, 14 15 Appellee, 16 17 v. 24-3261 18 19 PARWINDER SINGH 20 21 Defendant-Appellant. 22 _____________________________________ 23 24 For Appellee: AMANDA SHAMI, Amy Busa, Assistant United States 25 Attorneys for Joseph Nocella, Jr., United States 26 Attorney for the Eastern District of New York, 27 Brooklyn, NY. 28 29 For Defendant-Appellant: GARY SCHOER, Syosset, NY. 30 31

1 1 Appeal from a judgment of the United States District Court for the Eastern District of New

2 York (Chen, J.).

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

4 DECREED that the judgment of the district court is AFFIRMED.

5 Defendant-Appellant Parwinder Singh appeals from a judgment of the United States

6 District Court for the Eastern District of New York, entered on December 6, 2024, convicting him

7 of attempted obstruction of justice, in violation of 18 U.S.C. § 1512(c)(2), and escape from

8 custody, in violation of 18 U.S.C. § 751(a), and sentencing him to 44 months’ imprisonment, two

9 years’ supervised release, and a $200 special assessment.

10 Late on September 13 and into the morning of September 14, 2023, Singh repeatedly called

11 and texted Sadaf Anwar, who he had been romantically involved with, asking to see her. At

12 around 4:30 AM on September 14, when Anwar arrived near her home, Singh approached her.

13 After a brief argument, he broke her phone screen, repeatedly hit her, shoved her to the ground,

14 and then picked her up and carried her to his car. He then proceeded to drive Anwar from

15 Brooklyn to Queens, Staten Island, and New Jersey. Singh was arrested in New Jersey later that

16 morning and was indicted on kidnapping charges in the Eastern District of New York on

17 September 26, 2023. By superseding indictments, Singh was also charged with escape from

18 custody and attempted obstruction of justice. Following a July 2024 jury trial, Singh was

19 convicted of the obstruction and escape charges, but the jury failed to return a verdict on the

20 kidnapping charge.

21 On appeal, Singh argues that the evidence adduced at trial was insufficient to establish that

22 he committed attempted obstruction of justice. He urges, particularly in light of the fact that the

23 jury did not convict him of kidnapping Anwar, that his repeated requests that she change her story

2 1 amounted only to “asking her to tell the truth . . . .” Blue Br. at 25–26. Singh claims, “there

2 was sufficient doubt” that he had “corruptly” tried to influence her testimony in violation of 18

3 U.S.C. §1512(c)(2) to require that the jury’s verdict be set aside. Id. We assume the parties’

4 familiarity with the underlying facts, the procedural history of the case, and the issues on appeal,

5 which we reference only as necessary to explain our decision to AFFIRM.

6 * * *

7 We review a district court’s denial of a motion for a judgment of acquittal under Rule 29

8 de novo. See United States v. Persico, 645 F.3d 85, 104 (2d Cir. 2011). In assessing a

9 sufficiency of the evidence challenge, “we view the evidence in the light most favorable to the

10 Government with all reasonable inferences resolved in the Government’s favor.” United States

11 v. Requena, 980 F.3d 30, 43 (2d Cir. 2020). The “verdict must be upheld if any rational trier of

12 fact could have found the essential elements of the crime had been proved beyond a reasonable

13 doubt.” United States v. Valle, 807 F.3d 508, 515 (2d Cir. 2015). “The government’s proof

14 need not exclude every possible hypothesis of innocence, and where there are conflicts in the

15 testimony, we defer ‘to the jury’s determination of the weight of the evidence and the credibility

16 of the witnesses, and to the jury’s choice of the competing inferences that can be drawn from the

17 evidence.’” United States v. Best, 219 F.3d 192, 200 (2d Cir. 2000) (internal citations omitted)

18 (quoting United States v. Morrison, 153 F.3d 34, 49 (2d Cir.1998)); see also United States v. Abu-

19 Jihaad, 630 F.3d 102, 134 (2d Cir. 2010) (explaining that when reviewing a sufficiency challenge,

20 we “assum[e] that the jury resolved all questions of witness credibility and competing inferences

21 in favor of the prosecution”).

22 Singh argues that “there was sufficient doubt he had ‘corruptly’ tried to influence

23 [Anwar’s] testimony as to undermine the obstruction verdict.” Blue Br. at 26. Pointing to the

3 1 jury’s failure to reach a unanimous verdict on the kidnapping charge, Singh argues that any efforts

2 to persuade Anwar to recant or change her testimony could not have been done with a corrupt

3 purpose. Instead, such efforts were to convince her to tell the truth. We disagree.

4 To start, the jury’s failure to convict Singh on the kidnapping charge does not bear on our

5 sufficiency analysis for the obstruction conviction. Sufficiency of the evidence review “should

6 not be confused with the problems caused by inconsistent verdicts. [It] involves assessment by

7 the courts of whether the evidence adduced at trial could support any rational determination of

8 guilty beyond a reasonable doubt. This review should be independent of the jury’s determination

9 that evidence on another count was insufficient.” United States v. Powell, 469 U.S. 57, 67 (1984)

10 (internal citations omitted).

11 The evidence adduced at trial was more than sufficient for a juror to conclude that Singh,

12 both in his own repeated phone calls with Anwar and through outreach by others, corruptly

13 attempted to persuade Anwar to recant her allegations. For example, in one recorded telephone

14 conversation, Singh directed Anwar to attest that she told him to put her in the car because “you

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Related

United States v. Powell
469 U.S. 57 (Supreme Court, 1984)
United States v. Abu-Jihaad
630 F.3d 102 (Second Circuit, 2010)
United States v. Persico
645 F.3d 85 (Second Circuit, 2011)
United States v. Arthur Morrison
153 F.3d 34 (Second Circuit, 1998)
United States v. James Best
219 F.3d 192 (Second Circuit, 2000)
United States v. Requena
980 F.3d 30 (Second Circuit, 2020)
United States v. Valle
807 F.3d 508 (Second Circuit, 2015)

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Bluebook (online)
United States v. Singh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-singh-ca2-2026.