United States v. Douglas Richardson, No. 21-2370 (8th Cir. 2022)
Annotate this CaseCourt Description: [Per Curiam - Before Shepherd, Erickson, and Stras, Circuit Judges] Criminal case - Criminal law. The evidence was sufficient to support defendant's convictions for wire fraud and money laundering; claim of ineffective assistance of counsel would not be reviewed on direct appeal; Sixth Amendment challenge to the restitution order is foreclosed by circuit precedent - see U.S. v. Carruth, 418 F.3d 900, 904 (8th Cir. 2005).
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 21-2370 ___________________________ United States of America Plaintiff - Appellee v. Douglas A. Richardson Defendant - Appellant ____________ Appeal from United States District Court for the Western District of Missouri - Springfield ____________ Submitted: April 14, 2022 Filed: September 6, 2022 [Unpublished] ____________ Before SHEPHERD, ERICKSON, and STRAS, Circuit Judges. ____________ PER CURIAM. A jury found Douglas Richardson guilty of wire fraud and money laundering after he misappropriated over $9 million from others, including his employer. 18 U.S.C. §§ 1343, 1957(a). We affirm. Richardson made little effort to hide his crimes. He told two others, for example, that he took money from his employer’s account for his own use. He also defrauded several others who gave him cash to invest. Rather than doing what he promised, he used their funds to pay off his own debts. In the end, multiple witnesses—including the individuals he defrauded—told the jury what he had done. Their testimony, as well as other evidence, established Richardson’s fraudulent scheme, including his intent to defraud. See 18 U.S.C. § 1343 (wire fraud). The wire fraud then became the “specified unlawful activity” that allowed the jury to conclude that he had laundered money. 18 U.S.C. § 1957(a); see also id. §§ 1956(c)(7)(A), 1961(1). In short, the evidence was sufficient to establish every element of every count. Richardson’s other arguments fare no better. The ineffective-assistance-oftrial-counsel claim will have to await collateral review. See United States v. Ramirez-Hernandez, 449 F.3d 824, 826–27 (8th Cir. 2006) (explaining that this type of claim is “usually best litigated in collateral proceedings”). And the Sixth Amendment challenge to the restitution order is foreclosed by precedent. See United States v. Carruth, 418 F.3d 900, 904 (8th Cir. 2005) (explaining that judges may find the facts underlying a restitution order); see also United States v. Flynn, 969 F.3d 873, 881–82 (8th Cir. 2020) (making clear that the Supreme Court has not “silently overturn[ed] our precedent” in this area). We accordingly affirm the judgment of the district court.1 ______________________________ 1 The Honorable M. Douglas Harpool, United States District Judge for the Western District of Missouri. -2-
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