Case 5:23-cr-00357-GTS Document 34 Filed 09/15/25 Page 1 of 3
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
____________________________________
|
UNITED STATES OF AMERICA |
| Criminal No. 5:23-cr-357 (GTS)
v. |
|
CHRISTOPHER LLOYD TAYLOR, |
| Government Sentencing Memorandum
Defendant. |
____________________________________|
The United States of America, by and through its counsel of record, the United States
Attorney for the Northern District of New York, hereby files its sentencing memorandum
requesting, for the reasons set forth below, that the Court sentence the defendant to a sentence
consistent with the factors set forth in 18 U.S.C. § 3553(a) and a 3-year term of supervised release.
I
INTRODUCTION
On November 1, 2023, pursuant to a written Rule 11(c)(1)(A) plea agreement, the
defendant entered a plea of guilty to Count 1 of a one-count Information, which charges on or
about March 16, 2023, in Onondaga County in the Northern District of New York, the defendant
knowingly possessed a firearm, specifically: one “Spikes Tactical” AR-15 style rifle bearing
Model Number ST15, Serial Number SHM008427, with a barrel length measuring less than 16
inches long, which was not registered to him in the National Firearms Registration and Transfer
Record, in violation of 26 U.S.C. §§ 5841, 5861(d) and 5871. The defendant is scheduled to be
sentenced on October 7, 2025, in Syracuse, New York.
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II
APPLICABLE STATUTORY AND GUIDELINES PROVISIONS
The government agrees with the facts, criminal history category, guidelines calculation,
and statutory sentencing requirements set forth in the Presentence Investigation Report (“PSR”).
See Dkt. 25.
III
GOVERNMENT’S SENTENCING RECOMMENDATION
Based on all the information before the Court, including the information set forth in detail
in the PSR, the government would ask that the Court sentence the defendant to a sentence
consistent with the factors set forth in 18 U.S.C. § 3553(a) followed by a 3-year term of supervised
release.
The defendant’s acceptance of responsibility letter paints the picture of a man who has
gotten a wakeup call and realizes how important he is to his family and his need to be present for
them. His conduct since his arrest of immediately accepting responsibility for his actions is also a
positive indication that he understands the errors of his ways. The government truly hopes that
that is the case and trusts that the Court will craft a sentence that is appropriate in this matter. The
government would also ask that the Court follow that sentence with 3 years of supervised release
to help ensure that the defendant stays on the path he appears to be on. The term of supervised
release should assist him with his battle with substance abuse issues.
The sentence that the government recommends here is sufficient, but not greater than
necessary to comply with the sentencing purposes in 18 U.S.C. §3553(a)(2). This sentence reflects
the seriousness of the violation and provides adequate deterrence against future violations. In the
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ordinary case, the Commission’s recommendation of a sentencing range will ‘reflect a rough
approximation of sentences that might achieve §3553(a)’s objectives.’ Kimbrough v. United
States, 552 U.S. 85 (2007); see, e.g., Gall v. United States, 552 U.S. 38 (2007) (Guidelines are “the
product of careful study based on extensive empirical evidence derived from the review of
thousands of individual sentencing decisions”). Moreover, within-guidelines sentences promote
Congress’s goal in enacting the Sentencing Reform Act - “to diminish unwarranted sentencing
disparity.” Rita v. United States, 551 U.S. 338, 354 (2007).
Respectfully submitted this 15th day of September 2025.
JOHN A. SARCONE III
Acting United States Attorney
/s/ Geoffrey JL Brown
By:
Geoffrey J.L. Brown
Assistant United States Attorney
Bar Roll No. 513495
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