U.S. v. Minhas

Dist. Ct. did not err in sentencing defendant to 114-month term of incarceration on wire and mail fraud charges, even though said sentence was based, in part, on imposition of “substantial financial hardship” enhancement under section 2B1.1(b)(2) of USSG. Dist. Ct. could properly find that certain victims were “working people” of “modest means” who were not rich and who spent considerable time saving money to purchase airline tickets that, due to defendant’s actions, were not honored by airlines. Also, Dist. Ct. could properly conclude that victims who lost over $3,000 from defendant’s two fraudulent schemes suffered “substantial financial harm,” where Dist. Ct. examined each victim’s individual losses and considered impact statements indicating that victims had saved for long periods to go oversea on religious-based trip or had spent life savings in order to purchase said tickets. Moreover, where defendant’s schemes tended to target those seeking discount travel, Dist. Ct. could properly conclude from entire record that victims suffered substantial financial hardship.