United States v. Watts

CourtCourt of Appeals for the Second Circuit
DecidedApril 12, 2023
Docket21-2925(L)
StatusUnpublished

This text of United States v. Watts (United States v. Watts) 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. Watts, (2d Cir. 2023).

Opinion

21-2925(L) United States of America v. Watts

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 12th day of April, two thousand twenty-three.

Present: DEBRA ANN LIVINGSTON, Chief Judge, BARRINGTON D. PARKER, MICHAEL H. PARK, Circuit Judges. _____________________________________

MICHAEL WATTS,

Defendant-Appellant-Cross-Appellee,

v. 21-2925, 21-3028

THE UNITED STATES OF AMERICA,

Appellee-Cross-Appellant. * _____________________________________

For Defendant-Appellant-Cross-Appellee: JOSEPH W. RYAN, JR., Melville Law Center, Melville, NY.

For Appellee-Cross-Appellant: WHITMAN G.S. KNAPP, Assistant United States Attorney (Jo Ann M. Navickas, Kaitlin T. Farrell on the brief), on behalf of Breon Peace, United States

* The Clerk of Court is respectfully directed to amend the official caption as set forth above.

1 Attorney for the Eastern District of New York, Brooklyn, NY.

Appeal from a memorandum and order and sentencing and judgment of the United States

District Court for the Eastern District of New York (Seybert, J.).

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

DECREED that the judgment of the district court is AFFIRMED in part and REMANDED with

instructions to vacate the judgment and resentence.

Defendant-Appellant-Cross-Appellee Michael Watts (“Watts”) appeals from a November

18, 2021, judgment of the United States District Court for the Eastern District of New York

(Seybert, J.), convicting him, following a jury trial, of conspiracy to commit securities fraud, in

violation of 18 U.S.C. § 371; conspiracy to commit wire fraud, in violation of 18 U.S.C. §§ 1349,

1343; securities fraud, in violation of 15 U.S.C. §§ 78j(b), 78ff; conspiracy to commit money

laundering, in violation of 18 U.S.C. §§ 1956(h), 1957(a); and three counts of money laundering,

in violation of 18 U.S.C. § 1957(a). See United States v. Watts, No. 17-CR-0372 (JS), 2020 WL

6136211 (E.D.N.Y. Oct. 19, 2020). The district court sentenced Watts principally to a term of

imprisonment of one year and a day, and it imposed $4,430,354.03 in restitution and forfeiture in

the amount of $561,111. Watts argues that: (1) the government constructively amended his

indictment, and the district court abused its discretion in denying Watts’s motion for a new trial;

and (2) the district court erroneously calculated the amounts of forfeiture and restitution owed.

On cross-appeal, the government argues that the district court’s sentence of one year and one day,

which represents approximately a 95% downward variance from the advisory Sentencing

Guidelines range of 235 to 293 months, was substantively unreasonable. We assume the parties’

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

2 which we set out here only insofar as necessary to explain our decision to affirm in part and to

remand for resentencing.

I. Watts’s Appeal

At the start, we reject Watts’s argument that the government constructively amended the

indictment during summation for substantially the reasons explained in the district court’s

thorough Memorandum and Order of October 19, 2020. See GA353-61. The indictment

specifically alleges Watts’s and his co-conspirators’ use of sham documents to effectuate their

schemes. There is no requirement that all such documents be specifically identified in the

charging instrument, nor is it the case, as Watts claims, that the government introduced a new

theory of guilt, separate and apart from its ample evidence of illegal match trading, simply by

relying in summation on GX229-C – an exhibit which Watts himself signed, and which evidenced

his use of a sham consulting arrangement to secure the funds needed to pay the Boiler Room.

Here, we discern no indication in the record, much less a “substantial likelihood,” that Watts “may

have been convicted of an offense other than the one charged by the grand jury.” United States

v. Vebeliunas, 76 F.3d 1283, 1290 (2d Cir. 1996) (citations and internal quotation marks omitted).

See also United States v. Morgenstern, 933 F.2d 1108, 1115 (2d Cir. 1991) (noting that “where a

generally framed indictment encompasses the specific legal theory or evidence used at trial, no

constructive amendment occurs”).

Nor did the district court err – much less abuse its discretion – in denying Watts’s motion

pursuant to Rule 33 of the Federal Rules of Criminal Procedure for a new trial. See United States

v. Gramins, 939 F.3d 429, 444 (2d Cir. 2019) (noting that a district court’s Rule 33 determination

is reviewed for abuse of discretion). Contrary to Watts’s claim on appeal, the district court

properly concluded that the jury was entitled to find, based on ample trial evidence, that Watts

3 hired the Boiler Room first to keep afloat the share price of Hydrocarb Energy Corporation

(“HECC”) – the company in which his personal fortune was invested – and then to help him unload

his shares when the company’s failure became inevitable. Watts identifies no erroneous findings

in the district court’s 38-page opinion, nor any basis in the record to suggest that the district court

should have “harbor[ed] a real concern that an innocent person may have been convicted.”

United States v. James, 712 F.3d 79, 107 (2d Cir. 2013) (noting that such concern is prerequisite

to granting a Rule 33 motion) (citation and internal quotation marks omitted).

Turning finally to the district court’s calculation of the forfeiture and restitution amounts,

we identify no clear error or abuse of discretion, respectively, as to either calculation. For the

reasons explained by the district court at sentencing, the court properly included the trades of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Cutler
520 F.3d 136 (Second Circuit, 2008)
United States v. Daniel Fatico
603 F.2d 1053 (Second Circuit, 1979)
United States v. Seymour Morgenstern
933 F.2d 1108 (Second Circuit, 1991)
United States v. James Rattoballi
452 F.3d 127 (Second Circuit, 2006)
United States v. James and Mallay
712 F.3d 79 (Second Circuit, 2013)
United States v. Ingram
721 F.3d 35 (Second Circuit, 2013)
United States v. Gushlak
728 F.3d 184 (Second Circuit, 2013)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Pratheepan Thavaraja
740 F.3d 253 (Second Circuit, 2014)
United States v. Park
758 F.3d 193 (Second Circuit, 2014)
United States v. Sample
901 F.3d 1196 (Tenth Circuit, 2018)
United States v. Gramins
939 F.3d 429 (Second Circuit, 2019)
United States v. Mumuni
946 F.3d 97 (Second Circuit, 2019)
United States v. Zukerman
897 F.3d 423 (Second Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Watts, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-watts-ca2-2023.