United States v. Spirito (4th Cir. May 2022)
Fourth Circuit, Fraud Cases, Recent Circuit Cases
|The Fourth Circuit affirmed a defendant’s conviction for several fraud offenses but reversed his conviction for federal program fraud under 18 USC 666. At issue was whether Section 666 “criminalizes multiple conversions of less than $5,000, if the government must point to conversions that took place over more than one year to reach the $5,000 statutory minimum.” The Court held that Section 666 “requires each transaction used to reach the aggregate $5,000 requirement to occur within the same one-year period.”