United States v. House

House was convicted of six counts of bank fraud, 18 U.S.C. 1344, based on his involvement in a fraudulent automobile loan scheme. House was personally involved in applying to credit unions for 51 loans for fictitious auto sales in 2013; 36 were approved, resulting in total loan proceeds of $1.1 million. House personally kept $105,589.96, more than any one of his co-defendants.The court determined the appropriate Sentencing Guidelines range was 108-135 months’ imprisonment, and sentenced House to serve 108 months. The Seventh Circuit affirmed, rejecting House’s argument that the court improperly applied a three-level enhancement by finding that House was a manager or supervisor of the scheme under U.S.S.G. 3B1.1(b). The enhancement does not require an explicit finding that the defendant exercised direct control or authority over another participant. House was involved in the planning of the scheme, particularly with the idea to use fictitious car sales as a front for obtaining the loans. House used his business as the cover, which meant that he was necessarily involved in the key aspects of planning the scheme. House earned the most money and touched the highest number of transactions; the totality of his conduct qualified him for the enhancement. View "United States v. House" on Justia Law