United States v. Bouchard

── United States v. Bouchard ── Case No.: 24-2687 Court: Court of Appeals for the Second Circuit Date: March 30, 2026 Category: General 24-2687-cv United States v. Bouchard UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 30th day of March, two thousand twenty-six. PRESENT: BARRINGTON D. PARKER, RAYMOND J. LOHIER, JR., SARAH A. L. MERRIAM, Circuit Judges. ------------------------------------------------------------------ UNITED STATES OF AMERICA, Appellee, v. No. 24-2687-cv MICHAEL G. BOUCHARD, Defendant-Appellant. ------------------------------------------------------------------  FOR DEFENDANT-APPELLANT: MICHAEL G. BOUCHARD, pro se, Latham, NY FOR APPELLEE: JOSHUA ROTHENBERG, Assistant United States Attorney, for John A. Sarcone III, First Assistant United States Attorney for the Northern District of New York, Syracuse, NY Appeal from an order of the United States District Court for the Northern District of New York (Anne M. Nardacci, Judge). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the order of the District Court is AFFIRMED. Defendant Michael G. Bouchard, a former attorney representing himself, appeals from the September 26, 2024 order of the United States District Court for the Northern District of New York (Nardacci, J.) denying his petition for a writ of error coram nobis. Bouchard seeks to vacate his 2012 conviction for conspiracy to submit false statements to a financial institution, in violation of 18 U.S.C. § 371. In 2016 this Court affirmed that conviction on direct appeal. United States v. Bouchard, 828 F.3d 116, 128 (2d Cir. 2016). Three years later, we denied a certificate of appealability from the denial of his 28 U.S.C. § 2255 motion. Bouchard v. United States, No. 19-1913, 2019 WL 11689964 (2d Cir. Nov. 14, 2019). 2 We assume the parties’ familiarity with the underlying facts and the record of prior proceedings, to which we refer only as necessary to explain our decision to affirm. “The writ of error coram nobis is an extraordinary remedy that issues only in extreme cases.” United States v. Rutigliano, 887 F.3d 98, 108 (2d Cir. 2018) (quotation marks omitted). “We review de novo the legal standards that the district court has applied but review for abuse of discretion the court’s ultimate decision to deny the writ.” Doe v. United States, 915 F.3d 905, 909 (2d Cir. 2019). As the District Court accurately described, App’x 30, “[t]o secure coram nobis relief, a petitioner must show that (1) there are circumstances compelling such action to