United States v. Saint Clair

United States v. Saint Clair

Opinion

OPINION AND ORDER

CASTEL, U.S.D.J.:

A superseding indictment (the "Indictment;" Doc 62) charged defendant Asa Saint Clair with one count of wire fraud. Specifically, Saint Clair was charged with participating in a scheme to defraud investors in a cryptocurrency, "IGObit," by making material misrepresentations to investors regarding the relationship between the purported intergovernmental organization launching IGObit, the World Sports Alliance ("WSA"), and the United Nations ("UN").

Following an approximately one-week jury trial, Saint Clair was found guilty on the sole count of wire fraud. Before the Court are defendant's motions for acquittal or, alternatively, a new trial. Rules 29 & 33, Fed. R. Crim. P. For reasons [*2]  to be explained, the motions will be denied.

I. Saint Clair's Rule 29 Motion for Judgment of Acquittal

Saint Clair asserts that the evidence produced at trial was insufficient to support a conviction on the charge of wire fraud on three grounds: (1) the government failed to prove that Saint Clair made false or misleading statements to investors regarding WSA's relationship with the UN, (2) the government failed to prove that Saint Clair's actions were not done in good faith, and (3) the government failed to prove that the investor money spent by Saint Clair was not his earned income.

A. Legal Standard.

Rule 29 provides that "the court on the defendant's motion must enter a judgment of acquittal of any offense for which the evidence is insufficient to sustain a conviction." In reviewing such a motion, the court "must view the evidence in a light that is most favorable to the government, and with all reasonable inferences resolved in favor of the government." United States v. Anderson, 747 F.3d 51, 60 (2d Cir. 2014) (internal quotation marks omitted). A court must "defer[ ] to the jury's evaluation of the credibility of witnesses, its choices between permissible inferences, and its assessment of the weight of the evidence." United States v. Jones, 482 F.3d 60, 68 (2d Cir. 2006); United States v. Florez, 447 F.3d 145, 156 (2d Cir. 2006) ("We will not attempt to second-guess [*3]  a jury's credibility determination on a sufficiency challenge."). "The court may enter a judgment of acquittal only if the evidence that the defendant committed the crime alleged is nonexistent or so meager that no reasonable jury could find guilt beyond a reasonable doubt." United States v. Guadagna, 183 F.3d 122, 130 (2d Cir. 1999) (internal quotations and citations omitted). The court must deny the motion if "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." United States v. Aguilar, 585 F.3d 652, 656 (2d Cir. 2009) (quoting Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979)).

In order to prove a defendant guilty of wire fraud, the government must establish the existence of a scheme to defraud, that money or property were the object of the scheme, and that defendant used interstate wires in furtherance of that scheme. See United States v. Shellef, 507 F.3d 82, 107 (2d Cir. 2007). A fraudulent intent is essential to proving a scheme to defraud. United States v. D'Amato, 39 F.3d 1249, 1257 (2d Cir. 1994). But direct proof of defendant's fraudulent intent is not necessary; rather, "[i]ntent may be proven through circumstantial evidence, including by showing that defendant made misrepresentations to the victim(s) with knowledge that the statements were false." Guadagna, 183 F.3d at 130 (2d Cir. 1999). While a defendant's good faith is a defense to the charge of wire fraud, a belief that investors would ultimately make money from the fraudulent [*4]  scheme does not absolve a defendant of the requisite intent to defraud established by proof of knowingly made misrepresentations. See United States v. Ferguson, 676 F.3d 260, 280 (2d Cir. 2011); United States v. Shkreli, 779 Fed.Appx. 38, 40 (2d Cir. 2019).

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