United States v. Laird, No. 22-1978 (3d Cir. 2023)
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Corsica, Pennsylvania, with 357 residents and two businesses, is governed by a seven-person Council that meets once a month. In 2009, the Council hired Laird as secretary/treasurer—the Borough’s only paid staff position— at $12.50 per hour. Laird was the point person for Borough audits; only Laird and the Council President were authorized to sign Borough checks. Though two signatures were required, the President “common[ly]” provided Laird with signed blank checks. Between 2009-2017, Laird wrote unauthorized checks from the Borough’s bank account to herself and her husband. She paid her personal expenses by electronically transferring Borough funds and used the Borough’s credit card to purchase personal items. Laird embezzled $345,600.79. The Borough had to double property taxes to recoup some of its losses.
Laird pleaded guilty to 26 counts of wire fraud, 18 U.S.C. 1343, without a plea agreement. The PSR recommended a two-level increase under U.S.S.G 3B1.3 for Laird’s abuse of a position of trust and a 12-level increase under section 2B1.1(b)(1)(G) for loss between $250,000-$550,000. After decreasing three levels for Laird’s acceptance of responsibility, the PSR calculated a Guidelines sentencing range of 27-33 months’ imprisonment. The district court concluded that Laird’s legitimate salary did not reduce the total loss below $250,000 and applied the abuse-of-trust enhancement. The Third Circuit affirmed Laird’s 21-month sentence and a $266,050.79 restitution order.
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