U.S. v. Lewis

Record failed to contain sufficient evidence to support defendant’s money laundering conviction, where there was no evidence that defendant engaged or attempted to engage in monetary transaction using criminally derived property. Moreover, remand was required for new sentencing hearing on remaining wire fraud conviction, with Ct. of Appeals emphasizing that while defendant was “irritant” during trial process, Dist. Ct. cannot lengthen his sentence based upon such misconduct, especially where defendant represented himself during trial.