United States v. Reichel, No. 17-2562 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's conviction and sentence for wire fraud, filing for bankruptcy for the purpose of executing a scheme to defraud, and making false statements in relation to bankruptcy proceedings. The court rejected defendant's contention that the district court erred in denying his pretrial motion to sever the wire fraud counts from the bankruptcy-related counts, and held that joinder was appropriate here because the offenses were all connected to the common scheme. The court also held that the district court did not abuse its discretion in refusing to sever counts for trial under Federal Rule of Criminal Procedure 14; the convictions were supported by sufficient evidence; the district court did not abuse its discretion in denying defendant's post-trial motions to continue sentence and dismiss the superseding indictment; and the district court did not abuse its discretion by imposing sentencing enhancements for the amount of loss, use of sophisticated means, and abuse of a position of trust.