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Sentencing – Amount of loss

U.S. Court of Appeals  For the Seventh Circuit


Sentencing – Amount of loss

Where the entire loss was reasonably foreseeable to the defendant convicted of bank fraud, she was properly held accountable for it in calculating her offense level.

“The evidence of knowledge and coordination are just as strong in the present case as in Adeniji. Ms. Sykes, along with her fellow recruiters, coordinated their efforts with Hicks and took nearly identical steps to defraud their victims. Further, Ms. Sykes’s involvement in this scheme was not limited to her relationship with Hicks, the scheme’s leader. Rather, she personally knew and worked closely with at least one other recruiter in this scheme, namely Terence Sykes. On these facts, the district court was entitled to conclude that Ms. Sykes reasonably could foresee the total intended fraud loss caused by her codefendants. The district court did not clearly err in holding Ms. Sykes accountable for the total fraud loss caused by her codefendants.”


14-1510 U.S. v. Sykes

Appeal from the United States District Court for the Northern District of Illinois, Der-Yeghiayan, J., Ripple, J.

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