Pattern-Based Evidence and Sentencing Discretion in Armed Spree Robbery: United States v. Hampton

Introduction

United States v. Hampton (2d Cir. Apr. 21, 2025) concerns the appeal of Justin Hampton, convicted under the Hobbs Act for participating in a fourteen-count spree of armed convenience-store robberies in New York City. Hampton challenged (1) the sufficiency of evidence that he committed one of the robberies (October 19, 2021) and brandished a firearm, and (2) the procedural reasonableness of his 188-month sentence. The Second Circuit, sitting by summary order, affirmed both his conviction and sentence. Although non-precedential, the decision exemplifies how courts may rely on pattern evidence across related incidents to satisfy the “beyond a reasonable doubt” standard and the scope of a district court’s discretion in weighing sentencing factors when a defendant raises no contemporaneous objection.

Summary of the Judgment

The court applied the deferential sufficiency‐of‐the‐evidence standard from Cavazos v. Smith: if “any rational trier of fact” could find the elements beyond a reasonable doubt, the verdict stands. It held that cell-site data, surveillance footage, distinctive clothing and text messages—viewed in the aggregate and consistent across multiple robberies—created a permissible inference of Hampton’s participation and of his brandishing a “black and gold” firearm. On sentencing, the court applied Gall’s abuse-of-discretion review and found no procedural error. The district court had calculated the Guidelines range, considered the 18 U.S.C. § 3553(a) factors, and provided a reasoned explanation of Hampton’s greater culpability as the “gunman” and the brazen nature of his crimes.

Analysis

1. Precedents Cited

United States v. Raniere (55 F.4th 354): reaffirmed the standard for sufficiency review, requiring that evidence be viewed “in the light most favorable to the prosecution.”
United States v. Capers (20 F.4th 105): clarified the limits of reasonable‐jury inference under Hobbs Act prosecutions.
Cavazos v. Smith (565 U.S. 1): held that a verdict should only be overturned if “no rational trier of fact” could agree with the jury.
United States v. Chambers (2022 WL 6831645): endorsed use of evidence common to multiple related robberies to prove participation in each.
Gall v. United States (552 U.S. 38): set forth the abuse-of-discretion standard for reviewing procedural and substantive reasonableness of sentences.
United States v. Cavera (550 F.3d 180): enumerated district court procedural obligations at sentencing (calculating Guidelines, considering § 3553(a) factors, explaining its decision).
United States v. Banks (464 F.3d 184): clarified there is no requirement for a district court to address every argument in detail.
United States v. Sepulveda (850 F. App’x 98): underscored the need for “reasoned basis” in a sentencing explanation.
United States v. Smith (949 F.3d 60): established plain-error review when a defendant fails to object at sentencing.
Rita v. United States (551 U.S. 338): held that a district court need only demonstrate that it has considered the parties’ arguments and has a reasoned basis for its sentence.
United States v. Rosa (957 F.3d 113): reaffirmed that a detailed record of consideration suffices to avoid procedural error.

2. Legal Reasoning

On sufficiency, the court emphasized that a single incident need not be established in isolation. Rather, when multiple robberies share distinctive features—a getaway vehicle in proximity, a unique sweatshirt with a red tag, matching surveillance angles, consistent use of a black-and-gold firearm, and incriminating text messages—these “pattern-based” facts collectively permit a rational jury to infer Hampton’s identity and actions beyond a reasonable doubt. The ruling underscores that circumstantial evidence, including cell-site and digital‐forensic data, can satisfy the Hobbs Act’s elements when viewed holistically.

On sentencing, the court explained that procedural unreasonableness occurs only if the district court fails in key duties (e.g., calculating the Guidelines, considering § 3553(a) factors, explaining its reasoning). Here, the district court (1) computed the Guidelines range, (2) commented on the violent and “terrifying” nature of a fourteen-count spree, (3) contrasted Hampton’s greater role as the “gunman” with his co-defendant, and (4) noted the defendant’s repeated boldness even after law enforcement interventions. Hampton’s failure to object precludes anything beyond plain-error review; the record reflected a sufficiently reasoned sentencing decision.

3. Impact

Although summary orders do not have precedential effect, United States v. Hampton provides persuasive guidance on several fronts:

Pattern evidence across related offenses can coalesce into a legally sufficient case under the Hobbs Act, reducing the risk that a single‐incident challenge will succeed.
Digital forensics (cell-site data, text logs, geolocation, and device images) remain powerful tools to connect defendants to criminal episodes.
In sentencing, a district court’s general but reasoned discussion of § 3553(a) factors—especially when a defendant is silent on specific points—will typically survive procedural review.
Defendants who do not lodge contemporaneous objections risk forfeiting claims of procedural impropriety on appeal, as plain-error review imposes a heavy burden.

Complex Concepts Simplified

Hobbs Act robbery (18 U.S.C. § 1951): federal offense involving robbery affecting interstate commerce. Prosecution must prove (a) taking property from another, (b) by “actual or threatened force, violence, or fear,” and (c) effect on interstate commerce.
Sufficiency of evidence review: appellate courts ask whether any rational jury, viewing all evidence in the government’s favor, could find the defendant guilty beyond a reasonable doubt.
Brandishing enhancement (18 U.S.C. § 924(c)(1)(A)(ii)): using or possessing a firearm “in furtherance of a crime of violence” with brandishing carries mandatory consecutive prison terms.
§ 3553(a) factors: statutory sentencing considerations, including offense seriousness, history and characteristics of the defendant, need for deterrence, protection of the public, and consistency with similar cases.
Plain-error review: most deferred standard of appellate review; applied when a party fails to object in district court. Requires showing a clear or obvious error that affects substantial rights and seriously affects the fairness, integrity, or public reputation of judicial proceedings.

Conclusion

United States v. Hampton reaffirms that a robust web of circumstantial and pattern evidence can satisfy federal robbery statutes, even when direct eyewitness testimony is limited. It also confirms that district courts enjoy broad procedural discretion in sentencing so long as they calculate applicable ranges, consider § 3553(a) factors, and offer a reasoned basis for their decisions. For practitioners, this decision highlights the critical importance of comprehensive evidence packages in multi-incident prosecutions and the necessity of timely objections if defendants seek to preserve sentencing challenges on appeal.