Decision and Order — United States v. Eric Williams, Deshaun Williams and Melvin Darrell (W.D.N.Y., Dkt. 71)

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A Decision and Order, Document 71 in 25-CR-170 (JLS) (JJM), filed June 17, 2026, in the U.S. District Court for the Western District of New York, in United States v. Eric Williams, Deshaun Williams and Melvin Darrell, signed by John L. Sinatra, Jr., United States District Judge. The order addresses defendants' objections to the April 27, 2026 Report, Recommendation and Order of United States Magistrate Judge Jeremiah J. McCarthy. The Court accepts and adopts the recommendation to deny the Title III suppression motions and the Chestnut Street and iPhone suppression motion, and affirms the denial of the motions for a bill of particulars. The order is dated June 17, 2026, Buffalo, New York.

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,
v. 25-CR-170 (JLS) (JJM)

ERIC WILLIAMS; DESHAUN
WILLIAMS; MELVIN DARRELL,

Defendants.

DECISION AND ORDER

Defendants Eric Williams, Deshaun Williams, and Melvin Darrell are
charged in a six-count indictment with offenses related to possessing with intent to
distribute cocaine, maintaining drug-involved premises, and conspiracy to do the
same.! See Dkt. 1. Each Defendant filed pre-trial motions—both dispositive and
non-dispositive—described, as relevant, in more detail below.

United States Magistrate Judge Jeremiah J. McCarthy was designated to
hear and determine, and report and recommend on, all pre-trial proceedings under
28 U.S.C. §§ 636(b)(1)(A) and (B). Dkt. 23. On April 27, 2026, Judge McCarthy
issued a Report, Recommendation and Order (“R&R”), addressing all Defendants’
pre-trial motions. Dkt. 60. Each Defendant objected, to varying degrees, and the

Government responded in opposition.

1 Not each Defendant is charged in each count. See Dkt. 1.
DISCUSSION

I. Standards of Review

All Defendants objected to Judge McCarthy’s recommendations as to their
dispositive suppression motions, and Defendant Deshaun Williams objected to
Judge McCarthy’s order as to his non-dispositive motion for a bill of particulars.
Different standards of review apply to each type of objection.

On dispositive motions, a district court may accept, reject, or modify the
findings or recommendations of a magistrate judge. 28 U.S.C. § 636(b)(1); Fed. R.
Crim. P. 59(b)(8). A district court must review de novo those portions of a
magistrate judge’s recommendation to which a party objects. 28 U.S.C. § 686(b)(1);
28 U.S.C. § 686(b)(1); Fed. R. Crim. P. 59(b)(8). But a district court need not review
the recommendation of a magistrate judge to which no party objects. See Thomas
v. Arn, 474 U.S. 140, 149-50 (1988).

On the other hand, a district court may reverse a magistrate judge’s decision
and order on a non-dispositive motion that is “clearly erroneous or contrary to law.”
28 U.S.C. § 6386(b)(1)(A). A finding is “clearly erroneous only if ‘although there is
evidence to support it, the reviewing court on the entire evidence is left with the
definite and firm conviction that a mistake has been committed.” Atl. Specialty Ins.
Co. v. Coastal Env’t Grp. Inc., 945 F.3d 58, 63 (2d Cir. 2019) (citation modified). A
magistrate judge’s ruling is “contrary to law” if it fails to apply or misapplies
relevant statutes, case law, or rules of procedure. See, e.g., In re Hulley Enters.

Ltd., 400 F. Supp. 3d 62, 70 (S.D.N.Y. 2019) (citation modified).
Case 1:25-cr-00170-JLS-JJM Document71_ Filed 06/17/26 Page 3of6

The Court applies these standards of review, as applicable, to Defendants’
objections.

TI. Suppression Motions

A. Title III Suppression Motions

All Defendants moved to suppress evidence obtained pursuant to March 18,
and April 15, 2025 orders authorizing interception of visual, non-verbal conduct and
oral communications at two locations in Lockport, New York (the “Title III
suppression motions”). See Dkt. 42 (Melvin Darrell); Dkt. 43 (Eric Williams); Dkt.
47 (Deshaun Williams). Judge McCarthy recommended denying the Title III
suppression motions. See Dkt. 60, at 2—9.2

All Defendants objected to this recommendation. See Dkt. 61, at 5—7 (Melvin
Darrell, arguing that the R&R erred in concluding that the Title IIT application met
the necessity requirement); Dkt. 62, at 2-7 (Eric Williams, raising a similar
necessity argument, and arguing that the R&R erred in denying a Franks hearing
based on purported omissions from the Title III application); Dkt. 64, at 4—6
(Deshaun Williams, raising a similar necessity argument, raising a similar Franks
argument, arguing that the R&R erred in concluding that the Title III authorization
orders met the particularity and minimization requirements when the locations
were open to the public, and arguing that the R&R did not perform the required

Fourth Amendment analysis for the interception of visual, non-verbal conduct). The

2 Page references are to the numbering automatically generated by CM/ECF, which
appear in the header of each page.
Government responded to each Defendant’s objection. Dkt. 66 (Eric Williams); Dkt.
67 (Melvin Darrell); Dkt. 68 (Deshaun Williams). Eric Williams replied. Dkt. 70.

De novo review applies to these objections.’ See 28 U.S.C. § 636(b)(1); Fed. R.
Crim. P. 59(b)(8). This Court carefully reviewed Judge McCarthy’s
recommendation; the objections, responses, and reply; and the relevant record.
Based on that review, the Court accepts and adopts Judge McCarthy’s
recommendation to deny Defendants’ Title III suppression motions. As to Deshaun
Williams’s objection regarding the Fourth Amendment analysis for the interception
of visual, non-verbal conduct, the Court also notes that the Second Circuit has
applied the core requirements for Title III applications to the Fourth Amendment
analysis of video surveillance. See United States v. Biasucci, 786 F.2d 504, 510 (2d
Cir. 1986); see also Dkt. 68, at 17-18.

B. Chestnut Street and iPhone Suppression Motion

Deshaun Williams moved to suppress evidence obtained from a search of 118
Chestnut Street and an iPhone that was seized from that location. See Dkt. 47.
Judge McCarthy recommended denying this motion to suppress. Dkt. 60, at 9-10.

Deshaun Williams objected,‘ arguing that the R&R improperly denied the motion to

3 The Court recognizes that the parties dispute the relevant standard of review on
the Title III suppression recommendation. See Dkt. 67, at 2-3, 10; Dkt. 66, at 15;
Dkt. 68, at 15-16. The Court has reviewed the objections de novo and notes that
the result would be the same under either standard of review.

4 Wach Defendant moved to join the others’ objections. Dkt. 61, at 7; Dkt. 62, at 7;
Dkt. 64, at 9. To the extent that this objection applies to Melvin Darrell and Eric
Williams, the analysis applies to them as well.

4
suppress for failure to file an affidavit of standing, and that he is entitled to relief
on the merits. Dkt. 64, at 7-8. The Government responded. Dkt. 68.

De novo review applies to this objection. This Court carefully reviewed Judge
McCarthy’s recommendation, the objection and response, and the relevant record.
Based on that review, the Court accepts and adopts Judge McCarthy’s
recommendation to deny the Chestnut Street and iPhone suppression motion.

III. Motion for Bill of Particulars

All Defendants moved for a bill of particulars as to the conspiracy charged in
Count 1 of the indictment. See Dkt. 42; Dkt. 48; Dkt. 47. Judge McCarthy denied
these motions. Dkt. 60, at 10-12. Only Deshaun Williams objected.5 Dkt. 64, at 8—
9. The Government responded. Dkt. 68.

After reviewing Judge McCarthy’s order on this non-dispositive motion, the
objections, and the relevant record, the Court concludes that the denial was not
“clearly erroneous or contrary to law.” 28 U.S.C. § 636(b)(1)(A). The Court,

therefore, affirms Judge McCarthy’s order on this motion.

5 Hach Defendant moved to join the others’ objections. Dkt. 61, at 7; Dkt. 62, at 7;
Dkt. 64, at 9. This analysis applies to Melvin Darrell and Eric Williams as well.

5
CONCLUSION

For the reasons above and in the R&R, the Court:

e Accepts and adopts the R&R’s recommendations to deny Defendants’
suppression motions (Dkt. 60);

e Affirms the R&R’s order denying Defendants’ motions for a bill of
particulars; and

e Resolves the outstanding portions of Defendants’ underlying motions
(Dkt. 42; Dkt. 43; Dkt. 47), as set forth above.

SO ORDERED.

Dated: June 17, 2026
Buffalo, New York

A
JOHN L. SINATRA, JR.
UNI ED STATES DISTRICT JUDGE


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