United States v. Williams, No. 18-1267 (2d Cir. 2019)Annotate this Case
The Second Circuit affirmed defendant's conviction and sentence for arson and possession of unregistered Molotov cocktails. The court held that defendant failed to demonstrate that the district court plainly erred in instructing the jury on attempt; even assuming instructional error, defendant failed to show prejudice; defendant's argument that New York's ban on Molotov cocktails made it impossible to comply with the federal law mandating registration was foreclosed by United States v. Shepardson, 167 F.3d 120, 123‐24 (2d Cir. 1999); the district court did not err in denying defendant's motion to suppress the custodial statements defendant made to law enforcement; and defendant's challenges to the district court's handling of his criminal history at sentencing were rejected.