United States v. Sainfil, No. 20-778 (2d Cir. 2022)
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A jury convicted Defendant of conspiracy to commit armed bank robbery; armed bank robbery; and brandishing a firearm during a crime of violence. He was sentenced to 219 months in prison. Defendant appealed, challenging the district court’s denial of his motion for a new trial based on his counsel’s purported ineffective assistance in (a) failing to move to suppress Defendant’s pre-Miranda statement to an agent of the Federal Bureau of Investigation and (b) conceding to the jury that Defendant was outside the bank when it was robbed. Defendant also challenged the sufficiency of the evidence and argues that his sentence was procedurally and substantively unreasonable.
The Second Circuit affirmed the judgment of the district court. The court held that Defendant was not prejudiced by his trial counsel’s failure to move for suppression of his pre-Miranda statement to the FBI, where he made a similar post-Miranda statement that was undisputedly admissible. Further, that Defendant’s counsel did not provide objectively deficient performance when he conceded before the jury that Defendant was outside the bank on the day it was robbed, in light of Defendant’s post-Miranda admission, and abundant witness testimony placing Defendant outside the bank as a lookout. Moreover, there was sufficient evidence to support Defendant’s convictions and his sentence was procedurally reasonable. The district court did not clearly err in applying sentencing enhancements based on its conclusion that, given the circumstances in this case, it was reasonably foreseeable that Defendant’s co-conspirators would use physical restraints and body armor.
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