U.S. v. Titus

Federal 7th Circuit Court
Criminal Court
Sentencing
Citation
Case Number: 
No. 15-3054
Decision Date: 
May 12, 2016
Federal District: 
N.D. Ill., E. Div.
Holding: 
Vacated and remanded

Dist. Ct. committed procedural error when sentencing defendant to 36-month term of incarceration on bank fraud charge stemming from defendant’s scheme with others to obtain mortgages by using straw home buyers who made misrepresentations about employment on loan applications, where Dist. Ct. failed to make specific factual findings to support its conclusion that defendant was responsible for eighteen fraudulent transactions, that defendant’s conduct involved ten or more victims or that defendant’s conduct resulted in losses between $2.5 and $7 million. Fact that Dist. Ct. indicated that defendant was responsible for at least eight fraudulent transactions was insufficient. Ct. also noted that record lacked factual findings to support Dist. Ct.’s $3,760,859 restitution award.