United States v. Springer, No. 16-3498 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed Defendants Springer and Makohoniuk's convictions for bank fraud. The court held that there was sufficient evidence to demonstrate that defendants intended to cause a financial loss and that their scheme subjected the financial institutions to a risk of loss; the jury instructions did not put defendants at risk of being convicted of bank fraud based on trivial irrelevancies where the "materiality" qualification obviates any fear that the instructions could allow the jury to convict defendants for harmless misrepresentations; the jury had ample evidence to find materiality; the indictment fully and fairly apprised defendants of the charges they must meet at trial; submission of an aiding and abetting instruction was not error; the government did not violate Federal Rule of Evidence 404(b) by admitting evidence of the underlying scheme; the jury had sufficient evidence to conclude that the HUD-1s were false; the district court did not err by sua sponte severing Makohoniuk's trial from Springer's; and Makohoniuk knowingly waived his right to testify at trial.
Court Description: Arnold, Author, with Wollman and Gruender, Circuit Judges] Criminal case - Criminal law. In prosecution for bank fraud arising out of misrepresentations concerning short sales, the evidence was sufficient to support the defendants' bank fraud convictions as the government proved the defrauded entities were FDIC-insured and that the entities suffered a financial loss; under this court's prior precedents the government need not show an intent to cause a financial loss to prove bank fraud; challenge to jury instructions rejected; jury had ample evidence to find defendants' misrepresentations were material; claim that there was a variance between the indictment and the proof rejected; no error in giving an aiding-and-abetting instruction; district court advised defendant Makohoniuk of his right to testify and he knowingly waived the right.
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