United States v. Patel, No. 18-1685 (7th Cir. 2019)Annotate this Case
Patel pleaded guilty to five counts of wire fraud, 18 U.S.C. 1343, for his role in selling $179 million in fraudulent loans to an investment advisor. Patel delayed his sentencing date for a year while he purported to help recover funds for his victims. While on bond, just days before he was to be sentenced, Patel attempted to flee the U.S. and seek political asylum elsewhere. Agents arrested him just before he boarded a chartered flight to Ecuador. The government discovered that while on bond, instead of earning money for his victims through consulting fees and redevelopment projects, Patel and another used fictitious identities and entities to defraud an Iowa lender out of millions of dollars. Approximately $2.2 million of the money Patel had ostensibly earned for the fraud victims was newly‐stolen money. The court imposed a below-guidelines sentence of 25 years’ imprisonment. The Seventh Circuit affirmed the sentence as procedurally and substantively reasonable. Patel made a disparity argument, the government had the opportunity to respond, and the court addressed it on the record; nothing more is required. The court’s comments regarding Patel’s psychological state and motivations relate to factors that a court must consider at sentencing, 18 U.S.C. 3553(a)(1), (2)(A). There is no indication that the court “did not like” him and sentenced him inappropriately as a result.