United States v. Oloyede, No. 17-4102 (4th Cir. 2019)
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The Fourth Circuit affirmed defendants' convictions and sentences for conspiracy to commit wire fraud and related offenses based on an extensive online dating fraud scheme that induced elderly victims to transfer money to defendants' bank accounts based on postured romantic relationships.
The court held that the district court did not err in denying Defendant Mojisola's motion to suppress, holding that admission into evidence of data from her phone, which was the fruit of her opening it, presented no risk that coerced statements would be used against her at a criminal trial; the district court did not abuse its discretion in admitting into evidence under Federal Rule of Evidence 1006 a series of charts detailing selected deposits made into their bank accounts; and the district court did not abuse its discretion in denying Defendant Mojisola and Babatunde's motions for severance. The court rejected defendants' numerous claims of evidentiary errors and held that the district court did not err in giving the challenged jury instructions. Finally, the evidence was sufficient to support the convictions and defendants' claims of sentencing errors failed.
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