United States v. Brown

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT _______________ No. 98-30463 _______________ UNITED STATES OF AMERICA, Plaintiff-Appellee, VERSUS GREGORY DEAN BROWN, Defendant-Appellant. ******************** _______________ No. 98-30584 _______________ UNITED STATES OF AMERICA, Plaintiff-Appellee, VERSUS LEONARD STEVEN STEVE GRAVES, Defendant-Appellant. _________________________ Appeals from the United States District Court for the Western District of Louisiana _________________________ August 24, 1999 Before SMITH, WIENER, and BARKSDALE, Circuit Judges. JERRY E. SMITH, Circuit Judge: In this consolidated appeal, Leonard Graves appeals his money laundering convictions, a number of his fraud convictions, and his sentence. Gregory Brown sentence. We affirm Brown's sentence. appeals his sentence. We affirm Graves's fraud convictions, reverse his money laundering I. convictions, and vacate and remand his The fraud and money laundering charges of which Graves was convicted, and Brown's eighteen instances of overcharging were wire fraud conviction, relate to business charged against Graves as mail frauds, because dealings conducted at Steve Graves Chevrolet- the Louisiana Department of Motor Vehicles Pontiac-Cadillac, Inc. (“SGC”), an auto mailed the automobile titles. Graves was also dealership in Ruston, Louisiana. Graves was charged with money laundering the proceeds the dealer, president, and 41% owner of SGC, of the excessive fees. The jury found Graves and Brown managed its body shop. guilty on some of the counts and not guilty on others. The 120-count indictment against Graves alleged six distinct types of fraud,1 and for Graves was convicted of fraud based on each fraud allegation there was a SGC's financing the purchases of used cars corresponding money laundering charge. with “cash for gas.” In seven instances, SGC Graves was convicted on counts stemming advanced to the purchaser all or part of the from three of the six types of fraud and was down payment required by the financing convicted of money laundering the funds institutionSSunder the guise of giving the derived from these frauds. Brown pleaded buyer some “cash for gas”SSand increased the guilty to a type of fraud of which Graves was purchase price of the car by a corresponding not convicted. amount. This conduct constituted fraud, because the lending institution would not have The first type of fraud involved SGC's extended credit to the purchaser absent his charging car buyers more than the amount having some genuine equity interest in the authorized by state law for document and automobile. The counts of which Graves was license/title fees. SGC charged purchasers $59 convicted were charged as mail frauds, in document fees, which is $9 more than because SGC mailed loan documentation to Louisiana law permits; automobile dealerships General Motors Acceptance Corporation are allowed to charge only $35 for processing (“GMAC”), the financing institution.3 The paperwork and $15 for a notary fee. See LA. jury also found Graves guilty of money R.S. 6:956(E)(1), (2). For the license and title laundering the funds derived from cash for gas fees, which varied from vehicle to vehicle, frauds. SGC overcharged an average of $50 per automobile listed in the indictment.2 The The final form of fraud of which Graves was convicted also involved t he financing of used cars. For ten cars financed by Union 1 In addition to the four types of fraud Federal Credit Union, SGC, on behalf of the discussed below, the indictment alleged that buyer, forwarded to the credit union 25% of Graves, through SGC, engaged in “parts-to-labor” fraud and “scooping rebates” fraud. The former type of fraud involved SGC's billing automobile insurance companies for new parts but then (...continued) performing repairs using used parts and falsely $5.50 for handling, $5.00 to record a lien or charging the price difference as labor. The mortgage, and an amount specifically for the “scooping rebates” allegations involved SGC's license that varied, according to a Department of fraudulently denying the benefits of rebates to Motor Vehicles table, with the selling price of the customers and instead collecting the rebates for the vehicle. The total was the “license fee.” SGC dealership. Graves was acquitted of all charges typically collected $102 per vehicle as the license relating to parts-to-labor and scooping rebates fee. This resulted in an average overcharge of $50 frauds, but the district court found that such frauds per automobile listed in the indictment. had been established by a preponderance of the evidence and considered them in sentencing 3 One instance of “cash for gas” was Graves. charged as bank fraud, for the lender in that 2 instance was a bank. The jury acquitted Graves of The state charged $18.50 for the title, that charge and the corresponding money (continued...) laundering count. 2 the sale price, which the credit union of wire fraud, he was sentenced to an maintained in a savings account in the eighteen-month term of imprisonment and purchaser's name until the loan was paid off. restitution of $75,104.18.4 The court The dealership increased the sale price of the increased Brown's offense level by six to vehicle by a corresponding amount. As with account for a fraud loss greater than $70,000 “cash for gas,” this scheme had the effect of but no more than $120,000. See U.S.S.G. fraudulently inducing advances of credit, for § 2F1.1(b)(1)(G). After Brown's sentencing, the credit union believed that the 25% down the court granted the government’s “Motion to payment represented genuine purchaser equity Correct Judgment and Commitment Order” in the purchased automobiles. These counts asking the court to lower Brown's required were charged as bank frauds, and the jury restitution to victim insurance companies and returned a guilty verdict. It also found Graves individuals to $67,938.72. Brown contends guilty of money laundering the proceeds that this “lower loss figure” calls for an derived from the bank frauds. Graves does not increase of his base offense level of only five, appeal these bank fraud convictions, but he not six, levels and that his sentence is thus does appeal the corresponding money unduly severe. laundering convictions. The government charged Brown and Graves with filing fraudulent warranty claims. The indictment alleged ten instances in which SGC recovered warranty money from General Motors for repairs to vehicles when, in fact, the repaired vehicles were not covered by warranties. The government charged the fraudulent warranties as wire frauds, because General Motors credited the cost of repairs via computer. The jury found Graves not guilty of the wire fraud and corresponding money laundering charges. Brown, however, pleaded guilty to one count of wire fraud based on submission of a fraudulent warranty claim. In sentencing Graves, the court declined to group his fraud and money laundering convictions. Instead, it sentenced him solely on the basis of his money laundering offenses, which carry a tougher penalty than do fraud offenses. Compare U.S.S.G. § 2F1.1 (imposing a base offense level of six for mail and wire fraud) with U.S.S.G. § 2S1.1 (imposing a base offense level of 23 for money laundering). With an adjusted offense level of 30 and a criminal history category of I, the guidelines range was 97 to 121 months. The court departed downward by only one month, sentencing Graves to 96 months' incarceration. The court based the downward departure on its conclusion that Graves's conduct was 4 Brown was also given a three-year term outside the heartland of money laundering. of supervised release, which is to begin following his release from prison, and he was ordered to pay Based on Brown's plea of guilty to a charge an assessment to the crime victim fund. 3 Graves appeals his convictions on fraud first two elements but contends that there was counts stemming from excessive document and insufficient evidence to support a finding that license/title fees and “cash for gas” frauds. He he specifically intended to commit fraud. also appeals all his money laundering There was no specific intent, he argues, convictions and his sentence. Brown appeals because he did not know of the overcharges. only his sentence, asserting that it should be The jury, properly instructed,5 concluded reduced to reflect an error of fact discovered otherwise, and there was sufficient evidence to subsequent to sentencing. support its conclusion. II. 1. We first consider Graves's claim that there SGC overcharged $9 per vehicle for was insufficient evidence to support a number document fees ($59 rather than the maximum of his convictions. In evaluating a challenge to $50). Graves asserts that the government the sufficiency of the evidence, we view the presented no evidence that he knew of this evidence in the light most favorable to the overcharge; the evidence showed, he says, that verdict and uphold the verdict if, but only if, a he corrected the $9 overcharge as soon as he rational juror could have found each element learned from a Louisiana Automobile Dealers of the offense beyond a reasonable doubt. Association newsletter that the $59 charge was United States v. Giraldi, 86 F.3d 1368, 1371 too high. (5th Cir. 1996). Our review is de novo. United States v. Restrepo, 994 F.2d 173, 182 To maintain his claim of insufficient (5th Cir. 1993). We consider “the evidence, Graves must discount the testimony countervailing evidence as well as the evidence of Jim Smith, who had managed SGC's that supports the verdict” in assessing Finance and Insurance Office for a number of sufficiency of the evidence. Giraldi, 86 F.3d months during the indictment period. Smith at 1371. If “the evidence viewed in the light testified that the document fee was too high most favorable to the prosecution gives equal and that he had discussed that fact with Graves or nearly equal circumstantial support to a before Graves's discovery of the article theory of guilt and a theory of innocence,” a indicating that the fee was too high. Graves defendant is entitled to a judgment of acquittal. asserts that the jury could not rationally have United States v. Schuchmann, 84 F.3d 752, credited Smith's testimony over his own. 754 (5th Cir. 1996). The evidence is sufficient to sustain 5 In accordance with Fifth Circuit Pattern Graves's convictions of fraud stemming from Jury Instructions 1.37, the jurors were instructed as excessive fees and “cash for gas.” There is, follows: however, insufficient evidence to sustain his money laundering convictions. The word “knowingly,” as that term has been used from time to time in these A. instructions, means that the act was done The alleged offenses involving Graves's voluntarily and intentionally, not because of charging excessive document and license/title mistake or accident. fees were charged as mail fraud, a violation of 18 U.S.C. § 1341. The government must You may find that a defendant had prove beyond a reasonable doubt “(1) the knowledge of a fact if you find that the existence of a scheme to defraud; (2) the use defendant deliberately closed his eyes to what would otherwise have been obvious to of the mails to execute the scheme; and (3) the him. While knowledge on the part of the specific intent on the part of the defendant[] to defendant cannot be established merely by commit fraud.” United States v. Salvatore, demonstrating that the defendant was negligent, 110 F.3d 1131, 1136 (5th Cir.), cert. denied, careless, or foolish, knowledge can be inferred if 118 S. Ct. 441 (1997). Graves does not the defendant deliberately blinded himself to the contest the sufficiency of the evidence on the existence of a fact. 4 According to Graves, Smith, who was fired for evidence, he asserts, that he knew that Newton inadequacies in his paperwork, obviously did was failing to follow this order. not know what he was talking about, because he testified counterfactually that the dealership This assertion is simply incorrect. At least charged $80-100 as a document fee. When three pieces of evidence support a conclusion the government tried to conform his testimony that Graves knew the overcharges were to the uniformly charged $59 fee, the court continuing. First, Shelton testified that she sustained Graves's attorney's objection to told Graves that Newton was continuing to “leading.” overcharge. In addition, general manager Richard Anderson testified that he discussed Despite Graves's protests, Sm ith's the excessive license fees with Graves on testimony provided a sufficient evidentiary several occasions and that Graves had told him basis for the jury's conclusion that Graves that sometimes SGC overcharged and knew of the document fee overcharge. While sometimes undercharged, and things would Smith's testimony may not have been the most balance out in the end.8 Finally, Graves admits compelling, the jury was not irrational in that on the occasions Shelton reported crediting it over Graves's. It is certainly Newton's mistakes to Graves, he did not ask possible that Smith, who was finance manager her to provide refunds to the overcharged for only four months, could have forgotten the customers. exact figure charged as a document fee but remembered that the fee charged was too high This evidence, viewed in the light most and that he had discussed that fact with favorable to the verdict, adequately supports a Graves. The jury chose to believe Smith, and finding that Graves knew of the license/title fee its choice was not irrational.6 overcharges. The jury thus rationally could 2. Graves contends that the evidence does not 8 Graves unsuccessfully attempts to support a conclusion beyond a reasonable downplay this testimony. He asserts that doubt that he intended to overcharge license Anderson's testimony is unconvincing because (1) and title fees. He admits that the evidence the government offered no evidence as to the date would support a conclusion that he knew as of of the remark, which might have occurred before July 1994 that such overcharges were July 1994, when Shelton first found out that occurring, for there was evidence that Teresa license/title fee overcharges were occurring; (2) Shelton, Graves's office manager, told him at Shelton, who regularly attended the managers' that time that SGC was charging too high a meetings, never heard such a remark; and (3) Anderson lost all credibility when he portrayed fee.7 Graves notes, however, that the evidence NewtonSSthe very person who refused to adhere to shows that he immediately ordered Newton, Graves's order to lower the feeSSas complaining to his financial and insurance manager at the time, Graves that the fee was too high. to stop the overcharging. There is no None of these reasons requires discrediting Anderson's testimony. First, the jury could 6 reasonably have concluded that Graves's alleged See United States v. Guerrero, 169 F.3d remark to Anderson occurred after he learned that 933, overcharging was occurring, for the very subject 939 (5th Cir. 1999) (holding that on review of matter of the remark was the dealership's sufficiency of evidence to convict, court of appeals overcharging. Second, the fact that Shelton did not must accept credibility choices that support the hear the remark does not prove that it never verdict, and court may not reweigh evidence). occurred; the remark might have occurred outside her presence, or she might not have been paying 7 Indeed, the jury must have determined attention. Finally, the argument about Anderson's that Graves did not know of the overcharges before credibility should not persuade us to reverse a July 1994, because it acquitted him of those counts verdict, for credibility determinations are for the of mail fraud occurring before that date. jury. See Guerrero, 169 F.3d at 939. 5 have concluded that Graves, knowing of the offer proof that he eventually knew cash for overcharges and refusing to take effective gas was improper. It provided testimony from steps to stop them or remedy them through Dave Jeffers, a GMAC official who told refunds, intended the frauds. Accordingly, we Graves that “in our [GMAC's] judgment, [cash affirm Graves's fraud convictions stemming for gas] is a misrepresentation of the contract.” from SGC's overcharges of document and Graves further admits that if the government license/title fees.9 had proven that cash for gas transactions occurred with Graves's knowledge after this B. notification, then a rational jury could have Graves argues that the evidence supporting found him guilty of fraud. That was, in fact, his “cash for gas” fraud convictions is the government's theory of fraud; it explained insufficient, because there is no evidence that in summation that “after GMAC said to stop he continued to approve of cash for gas it,” “to submit the paperwork knowing it was financing after he learned that GMAC fraudulent, was fraud.” disapproved of it. Cash for gas financing, he asserts, is not obviously fraudulent. Graves's argument is that there was no Accordingly, the government could not have evidence that he approved cash for gas established Graves's criminal liability unless it transactions after he learned that such proved that he knew he was doing something financing was unacceptable to GMAC. The wrong by offering cash for gas; such proof was government never proved the date of Jeffers's necessary to establish the third prong of mail admonition about the impropriety of cash for fraudSSi.e., that he specifically intended to gas, and the jury, Graves argues, thus could commit fraud. See Salvatore, 110 F.3d at not have found beyond a reasonable doubt that 1136. any of the transactions occurred after Graves had knowledge that they were fraudulent. Graves admits that the government did Despite the absence of evidence that Jeffers's statement pre-dated the cash for gas transactions, a rational juror could have 9 Graves points to one other piece of concluded that Graves knew the charged cash evidence that, he says, shows that the verdict is for gas deals i nvolved material unsound. He notes that every employee of SGC misrepresentations and were thus fraudulent. who bought a car at the dealershipSSincluding A rational jury could assume that any astute Shelton, who was the centerpiece of the businessman would know that (1) a financing government's effort to prove that Graves violated institution that requires a down payment the law intentionallySSpaid the overcharge well after Graves ordered Newton to discontinue it. before extending credit is attempting to ensure Graves asserts that Shelton, who, on the that the debtor has an equity interest in the government's evidence, knew better, would not purchased good and will thus be “hurt” in have allowed herself to be overcharged, and the some way if the good is repossessed, and (2) fact that she did accept an overcharge indicates that the financing institution would be less likely to she (and thus Graves, as Shelton was allegedly the extend credit if the down payment was really source of his knowledge) did not know that the a “loan” from another entity (in this case, from license fee was still being overcharged. the dealership). This argument is unpersuasive. A rational jury The jury may thus have simply disbelieved could have concluded that Shelton allowed herself Graves's claim that he did not know cash for to be overcharged so as not to draw attention to the practice, or perhaps because she had gotten a good gas was dishonest. Indeed, Graves gave the deal from the dealership and did not want to be too jury a reason to doubt his candor toward demanding about small fees. Her willingness to GMAC with respect to the cash for gas pay the overcharge does not compel the conclusion transactions; he admits that even after he that she (and thus Graves) did not know of the learned from Jeffers that cash for gas was overcharge. fraudulent, general manager Anderson 6 continued to conduct such transactions, and when Graves learned that Anderson had done (i) with the intent to promote so, Graves neither undid the deals nor advised the carrying on of specified GMAC of what Anderson had done. Thus, unlawful activity; . . . .10 there was direct evidence that Graves, knowing a loan had been fraudulently induced, To obt ain a conviction under withheld material information. § 1956(a)(1)(A)(i), the government must prove beyond a reasonable doubt “[t]hat the Given that (1) any astute businessman defendant (1) conducted or attempted to would know cash for gas was wrong, and conduct a financial transaction, (2) which the (2) the evidence showed Graves's dishonesty defendant knew involved the proceeds of and lack of candor on particular cash-for-gas unlawful activity, (3) with the intent to transactions that he undoubtedly knew to be promote or further unlawful activity.” United fraudulent, the jury could have rationally States v. Cavalier, 17 F.3d 90, 92 (5th Cir. concluded, beyond a reasonable doubt, that 1994) (citations and internal quotations Graves knew cash for gas financing was omitted). Graves asserts that there was generally fraudulent. Hence, we affirm his insufficient evidence to establish that the fraud convictions on counts stemming from charged money laundering transactions were cash-for-gas financing. intended to promote any fraud committed at SGC.11 We agree. C. Each money laundering count on which The transactions the indictment charged as Graves was indicted was charged under money laundering consisted of expenditures, 18 U.S.C. § 1956(a)(1)(A)(i), which reads, in paid by checks written by SGC, that allegedly part: promoted the fraud.12 Graves contendsthat (A) Whoever, knowing that the propert y involved in a financial 10 transaction represents the proceeds of Subsequently, the money laundering some form of unlawful activity, statute defines “specified unlawful activity” to include mail and wire fraud. See 18 U.S.C. conducts or attempts to conduct such a §§ 1956(c)(7)(A), 1961(1). financial transaction which in fact involves the proceeds of specified 11 The money laundering statute unlawful activity proscribes, in separate provisions, “promotion” and “concealment” transactions. All the money laundering counts against Graves charged him with violating § 1956(a)(1)(A)(i), which proscribes the use of criminally derived funds “with the intent to promote” specified unlawful activities. Graves was not charged with undertaking transactions aimed at “concealing” criminally derived funds, which is a violation of § 1956(a)(1)(B). 12 The government, in selecting financial transactions to fulfill the actus reus requirement of the money laundering charges, picked benign business expendituresSSpurchases of goods and services necessary to maintain SGC's legitimate business operations. It did not have to do so. Courts have held that a promotion money laundering offense (continued...) 7 there was no evidence that the payment of Graves argues that such expenditures are not those checks was intended to promote any the sort of crime-promoting transactions fraud at SGC; the checks were simply criminalized by § 1956(a)(1)(A)(i), for the legitimate business expenses of the dealership. promotion element requires some identifiable Indeed, a review of the checks indicates that and affirmative advancement of the specified they were for “above board” expenses.13 criminal activity. In support of this claim, he points to a number of cases involving “promotion” money laundering in which the (...continued) court highlighted how the expenditures may occur when a defendant receives and deposits explicitly furthered specified unlawful criminally derived funds, in which case the deposit activity.14 He then contrasts those cases to the of the funds is the transaction intended to promote case at hand, in which the nexus between the the specified unlawful activity. See, e.g., United charged expenditures and any fraud activity is States v. Montoya, 945 F.2d 1068, 1076 (9th Cir. non-existent or weak. 1991). But the government chose not to indict Graves for depositing the proceeds of fraud. Graves also points to United States v. Instead, it made a strategic decision to focus on Jackson, 935 F.2d 832 (7th Cir. 1991), in SGC's spending transactions (i.e., the checks the which the defendant, who was both a preacher dealership wrote), not on SGC's depositing of and drug dealer, deposited drug proceeds into funds, perhaps because “receipt and deposit” his church's checking account. From the money laundering prosecutions are disfavored. church account, he wrote checks to pay for Such prosecutions have been criticized because beepers, mobile phones, and rent; he also the harm of the money laundering transaction (i.e., wrote some checks for cash. See id. at 841. the deposit) is not significantly greater than that of The defendant's drug runners used the beepers the underlying offense. See REPORT FOR THE to communicate with each other, and the court SENATE AND HOUSE JUDICIARY COMMITTEE ON therefore held that the beeper purchases were THE CHARGING AND PLEA PRACTICES OF FEDERAL intended to promote the specified unlawful PROSECUTORS WITH RESPECT TO THE OFFENSE OF conduct. Id. The checks for mobile phones, MONEY LAUNDERING 8-9 (1996) (report issued by rent, and cash, however, did not promote the the Department of Justice pursuant to Pub. criminal activity and thus did not constitute L. 104-38, 109 Stat. 334 (1995)). Indeed, the money laundering. Id. The court explained: Department of Justice issued a Blue Sheet to chapter 9-105.000 of the U.S. Attorney's Manual requiring consultation by a U.S. Attorney's Office with the Department before a receipt and deposit (...continued) case may be prosecuted. Id. at 13-14. See also (7) t-shirts, caps, coffee mugs; (8) yearbook United States v. Woods, 159 F.3d 1132, 1135 (8th advertisements; (9) a computer system lease; (10) Cir. 1998) (quoting 1996 DOJ Report to the effect advertising representation; (11) Graves's travel that money laundering statutes “should not be used expenses; (12) extended warranties on used in cases where the money laundering activity is automobiles; (13) glass replacement; (14) minimal or incidental to the underlying crime . . .”). automobile association membership fees; (15) Having chosen to prosecute Graves for spending photocopier supplies; and (16) a health plan. (not merely depositing) dirty money, the government was required to show that the 14 See, e.g., United States v. Nattier, 127 expenditures were conducted with an “intent to F.3d 655 (8th Cir. 1997), cert. denied, 523 U.S. promote” SGC's fraudulent activity. 1065 (1998) (checks paid for real estate that 13 promoted the specified embezzlement scheme); The allegedly laundered funds paid for United States v. Johnson, 971 F.2d 562 (10th Cir. (1) parts, paints, and materials; (2) the floor plan, 1992) (checks paid for office where defendant cars that had been traded in, floor plan interest, and conducted the fraud and luxury car that defendant a charge back; (3) software support and office used to impress investors); United States v. supplies; (4) conversions; (5) used cars; Hildebrand, 152 F.3d 756, 762-63 (8th Cir.) (in (6) disposal of waste oil and used oil filters; solicitation fraud, checks used to pay solicitors), (continued...) cert. denied, 119 S. Ct. 575 (1998). 8 The government did not prove that the ill-gotten gains to pay his callers, purchase cellular phones played the same roleSSor leads, and pay telephone bills so he could scam indeed any roleSSin Davis' drug more people.15 operations as the beepers. Likewise the rental payments and the checks written Despite the government's creative to cash; certainly these expenditures argument, we agree with Graves that there is maintained Davis' lifestyle, but more insufficient evidence that the charged than this is needed to establish that they expenditures were financial transactions promoted his drug activities. conducted “with the intent to promote the carrying on of specified unlawful activity.” Id. The problem with the government's position is that it ignores the intent aspect of the Graves argues that the expenditures promotion element. Section 1956(a)(1)(A)(i) charged in the money laundering counts of the is not satisfied by a showing that a financial indictment are analogous to the Jackson transaction involving the proceeds of specified defendant's expenditures on mobile phones and unlawful activity merely promoted the carrying rent: They were intended to support the on of unlawful activity. The provision has a dealership's legitimate business activities and specific intent element: The government must evince no intent to promote fraud. show that the “dirty money” transaction was conducted “with the intent to promote the The government insists that the carrying on of specified unlawful activity.” expenditures did promote fraud. Its theory, which the district court accepted, is that the This element is not satisfied by mere transactions charged in the indictment evidence of promotion, or even knowing promoted the ongoing and future criminal promotion, but requires evidence of activity at SGC, despite the fact that they were intentional promotion. By contrast, § expenditures on the basic operations of the car 1956(a)(1)(B), the moneylaundering provision dealership, because the operation of the applicable to “concealment” transactions, dealership was one grand scheme to defraud. requires only knowing concealment, indicating In other words, any legitimate operating that Congress intended a stringent mens rea expense that permitted SGC to stay in business requirement for promotion money laundering. and maintain or increase its customer base Thus, absent some evidence that a dirty money would also be an expenditure intended to transaction that in fact promoted specified promote fraud, because it would ensure a unlawful activity was conducted with the steady supply of potential victims. intent to promote such activity, a defendant The charged transactions, the government asserts, are akin to those in United States v. 15 The government also argues that Coscarelli, 105 F.3d 984 (5th Cir.), vacated, Graves's reliance on Jackson is misplaced. It 111 F.3d 376 (5th Cir. 1997), reinstated, maintains that Jackson is distinguishable because 149 F.3d 342 (5th Cir. 1998), a case involving the legitimate expenditures found not to have been telemarketing fraud. There, the defendant conducted with the intent to promote unlawful used the proceeds of his illegal activity to pay activity were personal expenditures. Here, by his co-conspirators and the operating expenses contrast, the charged expenditures were not for of their scheme. Id. at 990. The government personal items. The government's only support for maintains that the instant case is similar; this “personal versus non-personal” distinction is the Cavalier court's offhand observation that Graves used the funds from the fraud at SGC Jackson was “a case of a person simply using to pay SGC's operating expenses, enabling the illegally obtained funds to purchase personal dealership to defraud more customers. The items.” See 17 F.3d at 93. The Cavalier court did government also relies on United States v. not establish a principle that all “non-personal” Leonard, 61 F.3d 1181, 1186 (5th Cir. 1995), expenditures made with dirty money fall within the in which the defendant telemarketer used his ambit of § 1956(a)(1)(A)(i). 9 may not be convicted of promotion money source.16 The fact that Congress established a laundering under § 1956(a)(1)(A)(i). $10,000 per transaction threshold for convictions for simply spending dirty money This does not mean that there must always further supports our decision to read be direct evidence, such as a statement by the § 1956(a)(1)(A)(i) to require either direct defendant, of an intent to promote specified proof that the charged transaction was unlawful activity. In many cases, the intent to intended to promote specified unlawful activity promote criminal activity may be inferred from or proof of a type of transaction (such as the the particular type of transaction. For Jackson defendant's purchase of beepers) that, example, an intent to promote drug trafficking on its face, indicates an intent to promote such activities could be inferred from the Jackson activity. defendant's purchase of beepers, because Absent such proof, § 1956(a)(1)(A)(i) does beepers were not necessary to the defendant's not permit conviction of a defendant who, like legitimate business operations and played an Graves, deposits proceeds of some relatively important role in his drug trafficking scheme. minor fraudulent transactions into the operating account of an otherwise legitimate In the case at hand, had the government business enterprise and then writes checks out produced evidence of, say, payments for of that account for general business purposes. postage for mailing fraudulent warranty Accordingly, we reverse Graves's money claims, such payments might have provided laundering convictions. evidence of an intent to promote fraud. Mere evidence of legitimate business expenditures D. that were necessary to support SGC's non- Because the court determined Graves's fraudulent operations, however, was not sentence according to the sentencing enough to establish an intent to promote fraud guidelines applicable to money laundering (not at SGC, even though the expenditures may in fraud) offenses, our reversal of his money fact have promoted SGC's fraudulent activities laundering convictions requires that he be by increasing the number of potential fraud resentenced. We therefore vacate his sentence victims. and remand for resentencing under the guidelines applicable to fraud offenses. We have previously stressed the importance of not turning the “money laundering statute III. into a 'money spending statute.'” See Leonard, Brown pleaded guilty to wire fraud 61 F.3d 1181, 1185 n.2 (quoting United States stemming from a fraudulent warranty claim. v. Sanders, 928 F.2d 940, 946 (10th Cir. In sentencing Brown, the court increased his 1991)). Strictly adhering to the specific intent offense level by six, pursuant to U.S.S.G. requirement of the promotion element of § 2F1.1(b)(1)(C), to account for a fraud loss § 1956(a)(1)(A)(i) helps ensure that the money greater than $70,000 but less than $120,000; laundering statute will punish conduct that is the court determined that the loss totaled really distinct from the underlying specified $75,104.18. Brown was sentenced to eighteen unlawful activity and will not simply provide months' imprisonment and ordered to make overzealous prosecutors with a means of restitution totaling $75,104.18. imposing additional criminal liability any time a defendant makes benign expenditures with funds derived from unlawful acts. 16 See D. Randall Johnson, The Criminally In a separate money laundering statute, Derived Property Statute: Constitutional and 18 U.S.C. § 1957(a), Congress did criminalize Interpretive Issues Raised by 18 U.S.C. § 1957, the mere spending of “criminally derived 34 WM. & MARY L. REV. 1291, 1302 (1993) property that is of a value greater than (discussing Sanders and noting that “[u]nlike $10,000” with knowledge of the unlawful section 1956, section 1957 is indeed a 'money spending statute' . . . .”). 10 After the sentencing, the government filed a “Motion to Correct Judgment and Commitment Order” that advised the court that the “figure ordered for restitution to the victim insurance companies and the individuals is incorrect. The correct amount is lower, $67,938.72.” The district court granted the motion. Brown argues that lowering the amount of restitution owed the defrauded insurance companies and individuals moves him out of the $70,000 to $120,000 bracket of U.S.S.G. § 2F1.1(b)(1) and into the $40,000 to $70,000 bracket, for which only a five level increase is required. Brown's argument is meritless. The $75,104.18 loss the district court found attributable to his conduct included two components: loss to insurance companies and individuals, which totaled $69,548.43, and loss to General Motors Corporation, which totaled $5,555.75. The amendment to Brown's judgment affected only the amount he owed in restitution to “20 victim insurance companies and 15 individuals.” There was no adjustment to the amount due General Motors as restitution. Summing the lower figure, $67,938.72, and the amount owed General Motors, $5,555.75, yields a total restitution of $73,494.47SSa sum that still warrants a six- level increase under § 2F1.1(b)(1). Accordingly, the sentence is correct, despite the amended amount of restitution. For the foregoing reasons, Graves's fraud convictions are AFFIRMED, and his money laundering convictions are REVERSED. Graves's sentence is VACATED and REMANDED for resentencing according to the sentencing guidelines applicable to fraud offenses. Brown's sentence is AFFIRMED. 11