United States v. Thai

CourtCourt of Appeals for the Second Circuit
DecidedJanuary 14, 2026
Docket23-8037
StatusUnpublished

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

Opinion

23-8037-cr United States v. Thai

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 14th day of January, two thousand twenty-six.

PRESENT: AMALYA L. KEARSE, JOHN M. WALKER, JR., JOSEPH F. BIANCO, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 23-8037-cr

LAN NGOC TRAN, MINH DO, DAT NGUYEN, TAM THANH DO, AKA JOHNNY, AKA LONG THANH, AKA SON, L.V. HONG, AKA LV HONG, TAN LAI, BAO HUNG TRAN, JIMMY NGUYEN, HOANG HUY NGO, QUANG VAN NGUYEN, NIGEL JAGMOHAN, TUAN LEE, AKA DURANIA MICHAEL, AKA LITTLE COBRA,

Defendants-Defendants,

DAVID THAI,

Defendant-Appellant. _____________________________________ FOR APPELLEE: MEGAN LARKIN (Whitman G.S. Knapp, on the brief), Assistant United States Attorneys, for John J. Durham, United States Attorney for the Eastern District of New York, New York.

FOR DEFENDANT-APPELLANT: MURRAY E. SINGER, Port Washington, New York. Appeal from an order of the United States District Court for the Eastern District of New

York (Carol B. Amon, Judge).

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

DECREED that the order of the district court, entered on December 1, 2023, is AFFIRMED.

Defendant-Appellant David Thai appeals from the district court’s denial of his third motion

for compassionate release, pursuant to 18 U.S.C. § 3582(c)(1)(A). 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 to affirm.

On March 30, 1992, a jury convicted Thai of numerous crimes related to his participation

in, and leadership of, a racketeering enterprise known as the “Born to Kill” gang, which engaged

in violent criminal activity in Chinatown’s Canal Street area in lower Manhattan. On October 23,

1992, the district court sentenced Thai principally to two concurrent terms of life imprisonment.

On appeal, this Court affirmed the convictions, with the exception of a reversal of the charge in

Count Fifteen (conspiracy to commit assault in aid of racketeering) which was subsequently

dismissed by the district court and did not impact his life sentence. See generally United States v.

Thai, 29 F.3d 785 (2d Cir. 1994).

In November 2019, Thai filed a motion for compassionate release because of his poor

health. In March 2020, Thai argued in a supplemental filing that the COVID-19 pandemic posed

a significant risk to his health. In April 2020, the district court denied the motion. More

specifically, the district court concluded that, although Thai established an extraordinary and

2 compelling circumstance, i.e., a serious physical condition in the form of Shy Drager disease and

cardiac issues, the relevant Section 3553(a) factors “overwhelmingly militate[d] against a

modification of Thai’s life sentence[.]” App’x at 117. In particular, the district court emphasized,

inter alia, the extremely violent nature of Thai’s conduct as the leader of a gang:

Thai merited the life sentence he received. “Born to Kill,” the gang Thai led, systematically targeted Asian individuals, on the assumption that Asian victims would be most intimidated by the gang’s violence and least likely to report its crimes to the police. Thai’s leadership role in the gang involved, among other things, maintaining “safe houses” for gang members, planning robberies and supplying weapons to gang members selected to carry them out, and ordering the violent acts themselves. Among the violent acts orchestrated by Thai was the murder of a robbery victim who had cooperated with the police; the victim was executed in front of his 12-year old nephew. Thai also bore the responsibility for the violence perpetrated by the men that he led, which included, among other violent acts, shooting another robbery victim in the head after stabbing him and systematically tying up and brutalizing other robbery victims, who were often women. Thai’s violence was also directed to the gang members themselves. As the Second Circuit noted in affirming Thai’s conviction: “Discipline was strict, and gang members who disobeyed orders or who were suspected of cooperating with the police or of keeping the proceeds of robberies for themselves, instead of turning them over to Thai, suffered violent retribution.”

Id. at 115 (quoting Thai, 29 F.3d at 795) (internal citations omitted). In addition, with respect to

Thai’s history and characteristics, the district court explained that “his history of violence began

earlier than even the charged crimes,” noting that the Presentence Report indicated that “he

personally murdered two members of a rival gang” in 1989. Id. at 116. Finally, although

acknowledging that “Thai [had] presumably tried to better himself in prison by taking numerous

educational courses and doing well,” and that such rehabilitation was “commendable,” the district

court found “Thai’s apparent lack of remorse” to be “particularly troubling,” noting that his

statements in his motion papers about the reasons for his violent conduct—such as that he was

“‘young, foolish and uneducated’”—“convey[ed] no regret for his actions or the harm caused to

his many victims.” Id. (internal citation omitted).

3 In May 2020, Thai again moved for compassionate release, asserting again that the

COVID-19 pandemic increased his health risks and that there had been confirmed cases of

COVID-19 in the facility in which he was incarcerated. In June 2020, the district court denied the

motion, reiterating that it had denied Thai’s prior motion based

on the fact that the § 3553(a) factors—namely, the nature and circumstances of the offense; the history and characteristics of the defendant; and the need for the sentence to reflect the seriousness of the offense, to promote respect for the law, and to provide a just punishment for the offense—outweighed any ‘extraordinary and compelling’ circumstances, including the ongoing COVID-19 pandemic, put forth by Thai.

Id. at 123. More specifically, the district court emphasized that the fact that there were confirmed

cases of COVID-19 at Thai’s facility did “not present circumstances different enough to overcome

the § 3553(a) factors, which [the] Court [had] already found weigh[ed] strongly against Thai’s

release.” Id.

In August 2023, Thai filed his third motion for compassionate release on the grounds that

his medical issues and post-sentencing rehabilitation supported early release. In December 2023,

the district court denied the motion. In particular, the district court “consider[ed] whether Thai

[had] presented new evidence that alter[ed] [its] previous analysis of [the Section 3553(a)] factors”

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