Norman Seabrook served for many years as president of the New York City Correction Officers Benevolent Association (COBA). In that role, Seabrook exercised control over millions of dollars in union funds and occupied a position of trust with respect to COBA’s membership. While serving in that role, Seabrook directed approximately $20 million of COBA funds into investments with Platinum Partners, a hedge fund founded by Murray Huberfeld. In return, Seabrook received a “kickback” for his personal benefit, in the form of $60,000 in cash, stuffed into a luxury handbag and delivered by intermediary Jona Rechnitz. Rechnitz later cooperated with law enforcement and pleaded guilty pursuant to a cooperation agreement. Seabrook and Huberfeld were initially tried together, but that trial ended in a mistrial. After reassignment of the case, Huberfeld entered a plea to a different offense, while Seabrook proceeded to retrial, where a jury found him guilty of conspiracy to commit honest services wire fraud and substantive honest services wire fraud.
In 2019, the U.S. District Court for the Southern District of New York sentenced Seabrook to 58 months’ imprisonment, applying a two-level sentencing enhancement for abuse of a position of trust based on Seabrook’s role as union president. The Second Circuit affirmed that sentence on direct appeal.
Huberfeld and Rechnitz followed materially different paths. Rechnitz cooperated and pleaded guilty, leading to a substantially reduced sentence. Although Judge Hellerstein initially sentenced Huberfeld to 30 months’ imprisonment, the Second Circuit vacated that sentence upon finding that the commercial bribery sentencing guideline should not have been used. Huberfeld was ultimately sentenced to 7 months’ imprisonment
While incarcerated, Seabrook moved for compassionate release, arguing that the disparity between his 58-month sentence and the significantly shorter sentences imposed on his co-defendants constituted an extraordinary and compelling reason for relief. The district court agreed, reasoning that Huberfeld’s successful appeal and resentencing “changed the calculus” and created an unjust sentencing disparity. The district court reduced Seabrook’s sentence to time served, approximately 21 months.
The Second Circuit reversed. The Court emphasized that sentencing disparities of this nature are neither unusual nor extraordinary when defendants are not similarly situated. Seabrook went to trial twice and was convicted of more serious honest services offenses, while his co-defendants pleaded guilty to different crimes, accepted responsibility, and — in Rechnitz’s case — provided substantial assistance to the government. Those differences properly resulted in different guideline provisions, offense levels, and advisory ranges. The Court stressed that it should be expected, not extraordinary, that a defendant who proceeds to trial receives a longer sentence than co-defendants who plead guilty and cooperate.
The Court also noted that Seabrook’s sentence was supported by unique aggravating factors – namely, his abuse of his position of trust as union president to facilitate the scheme. The Second Circuit therefore directed reinstatement of Seabrook’s original sentence.
United States v. Seabrook, 2025 WL 3484616 (2d Cir. Dec. 4, 2025).