The United States Court of Appeals for the Second Circuit has upheld the sentence of Adama Sow, who was convicted of trafficking in counterfeit goods. The court's decision, issued on November 3, 2026, confirms a district court ruling that sentenced Sow to 24 months in prison, followed by three years of supervised release and ordered her to pay $1.5 million in restitution. This ruling is significant as it reinforces the legal consequences of engaging in counterfeit goods trafficking, a crime that affects numerous luxury brands.

Adama Sow was charged after law enforcement discovered over 3,000 counterfeit items in storage units she rented at Gotham Mini-Storage in Manhattan, New York. The items included clothing, shoes, and accessories bearing counterfeit luxury brand marks. Sow pled guilty to one count of trafficking in counterfeit goods without a plea agreement, leading to her sentencing by the district court.

The case began when authorities executed search warrants in October 2021, recovering a large quantity of counterfeit items linked to Sow. Following her guilty plea, the district court held a two-day hearing to resolve disputes regarding the sentencing guidelines applicable to her case. The hearing included testimony from employees of the storage facility and an expert who assessed the value of the counterfeit goods.

The district court found that Sow played a significant role in the trafficking operation, applying a two-level increase for her aggravating role and a twenty-level increase based on the estimated value of the counterfeit goods. Ultimately, the court determined that Sow's total offense level warranted a sentence of 24 months, which was below the advisory range suggested by the U.S. Sentencing Guidelines.

On appeal, Sow raised three main challenges to her sentence. She argued that the district court erred in its consideration of a specific statute that encourages non-custodial sentences for first-time offenders, claimed her sentence was procedurally unreasonable due to unsupported enhancements, and contended the court abused its discretion in ordering restitution. The Second Circuit, however, found no merit in her arguments.

The court ruled, "The district court did not give 'blind deference to the Guidelines.'" It emphasized that the district court had conducted an independent review of the sentencing factors and imposed a significant downward variation from the Guidelines range. The court also noted that Sow's involvement in an ongoing business of selling counterfeit goods warranted a custodial sentence, stating that her actions were not typical of a first-time offender.

Furthermore, the court upheld the district court's findings regarding the aggravating role enhancement, indicating that Sow had exercised control over others involved in the crime. The testimony from the Velazquez brothers, who worked at the storage facility, supported the conclusion that Sow had assistants working under her direction.

Regarding the value of the counterfeit goods, the court found that the district court's determination was based on credible evidence, including expert testimony that assessed the retail value of the seized items. The court stated that the district court had reasonably estimated the value of the counterfeit goods and that the enhancements applied were consistent with the U.S. Sentencing Guidelines.

Additionally, the court affirmed the restitution order, which required Sow to pay $1.5 million to the affected luxury brands for their investigation costs. The Second Circuit agreed that the brands suffered pecuniary loss as a result of Sow's actions, noting that the harm caused by counterfeit sales undermines the exclusive nature of luxury brands.

This ruling has broader implications for the enforcement of laws against counterfeit goods trafficking. It underscores the seriousness with which the courts view such offenses and the potential for significant penalties, including imprisonment and restitution, for those found guilty.

Looking ahead, it is unclear if Sow will seek further appeals in this matter. The court's ruling reinforces the legal framework surrounding counterfeit goods and sets a precedent for similar cases in the future, emphasizing the importance of protecting intellectual property rights.