United States v. Sharee Hall

MEMORANDUM

Sharee Hall (Hall) appeals her conviction on one count of wire fraud, 18 U.S.C. § 1343 , and one count of money laundering, 18 U.S.C. § 1957 . We have jurisdiction under 28 U.S.C. § 1291 and we affirm.

Hall advances four challenges to her convictions: (1) that there was insufficient evidence that the funds involved in her money laundering conviction were the “proceeds” of specified criminal activity; (2) that there was insufficient evidence to convict her of wire fraud because the government only presented circumstantial evidence that she was directing the transfers; (3) that the district court constructively amended the Indictment by instructing the jury on vicarious liability; and finally (4) that the district court erred in its response to the jury’s question regarding the scope of vicarious liability. We deal with each challenge in turn.

/. The Money Laundering Conviction

Hall argues that she could not have laundered the “proceeds” of the wire fraud because she was acquitted of the two charged wire fraud counts that would have made funds available at the time she purchased the $102,500 cashier’s check that underlies the money laundering count. In order to obtain…