United States v. Pierce

SUMMARY ORDER Defendants-appellants Latanya Pierce and Ifeanyichukwu Eric Abakporo appeal from the District Court’s December 4, 2014 judgments of conviction, which followed their three-week jury trial. Defendants raise numerous arguments in their counseled briefs. Abakporo also raises several additional arguments in a separate brief that he filed pro se. 1 *118 Upon independent review of the record and relevant law, we affirm, substantially for the reasons stated by the District Court in the pertinent oral and written rulings and decisions it issued before, during, and after trial. As for defendants’ arguments that were not presented to the District Court, we have reviewed them carefully, and find them equally unpersuasive. CONCLUSION We have considered all of defendants’ arguments and find them to be without merit. For the reasons stated above, we AFFIRM the District Court’s December 4, 2014 judgments of conviction. Footnotes [1] Abakporo was a licensed attorney before he was automatically disbarred as a result of his conviction in this case. See In re Ifeanyichukwu Eric Abakporo, 130 A.D.3d 24, 8 N.Y.S.3d *118 587 (2015). While “[i]t is well established that a court is ordinarily obligated to afford a special solicitude to pro se litigants,” it is also well established that "a lawyer representing himself ordinarily receives no such solicitude at all.” Tracy v. Freshwater, 623 F.3d 90, 101-02 (2d Cir.2010). Because the rationale for this latter rule is that an attorney "is experienced in litigation and familiar with the procedural setting presented,” id. at 102, it extends to disbarred attorneys such as Abakporo, cf. Mitchell v. Con Edison, 531 Fed.Appx. 140, 141 (2d Cir.2013) (summary order) (holding that a disbarred attorney is not entitled to special solicitude); In re Truong, 327 Fed.Appx. 260, 262 (2d Cir.2009) (summary order) ("[Although [the appellant] is proceeding pro se, he is an attorney, albeit a disbarred one.”). Accordingly, we afford no special solicitude to Abakporo here.