United States v. Sealed Defendant One, No. 21-118 (2d Cir. 2022)
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Defendant appealed from a judgment of conviction following his guilty plea to one count of transmitting a threat in interstate commerce, one count of threatening to assault a federal law officer, and one count of obstruction of justice. At a sentencing proceeding conducted by videoconference and under seal, the district court sentenced Defendant principally to eighty-four months’ imprisonment. On appeal, Defendant argues that (1) the government breached the plea agreement, (2) his sentence was procedurally unreasonable, and (3) the district court erred in conducting his sentencing by videoconference.
The Second Circuit affirmed. The court held that (1) the plea agreement expressly provided for the government to take the very actions Defendant now characterizes as breaches of that agreement, (2) the district court provided adequate notice and factual support for the sentencing variances and enhancements it applied, and (3) Defendant knowingly and voluntarily waived his right to be physically present at sentencing. The court also held as a matter of first impression – that sealed sentencings conducted by videoconference do not implicate Federal Rule of Criminal Procedure 53’s prohibition on “the broadcasting of judicial proceedings from the courtroom” or the procedural requirements associated with the CARES Act’s exception to Rule 53.
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