United States v. Lisa Lievanos

MEMORANDUM

Lievanos appeals multiple convictions and the sentence resulting from her participation in a loan fraud conspiracy that submitted false loan applications to sub-prime lenders in order to buy various properties.

1. Batson claims: The prosecutor gave race-neutral reasons for exercising peremptory challenges to dismiss three African-American jurors. See Batson v. Kentucky, 476 U.S. 79, 98 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986); see also Purkett v. Elem, 514 U.S. 765, 768 , 115 S.Ct. 1769 , 131 L.Ed.2d 834 (1995) (per curiam). Specifically, G. admitted that her religious beliefs would affect her ability to sit in judgment of Lievanos. W. agreed with the district court that his family’s negative experiences with subprime lenders created “emotional issues with this whole business of subprime lending.” L. wasn’t candid about his previous work for a subprime lender.

The district court’s finding that the dismissals weren’t the result of purposeful racial discrimination is supported by the record. See Snyder v. Louisiana, 552 U.S. 472, 477 , 128 S.Ct. 1203 , 170 L.Ed.2d 175 (2008). The prosecutor dismissed for cause a non-minority juror who shared G.’s religious scruples. See…