United States Commodity Futures Trading Commission v. Husam Tayeh

CourtCourt of Appeals for the Eleventh Circuit
DecidedMarch 2, 2021
Docket20-11017
StatusUnpublished

This text of United States Commodity Futures Trading Commission v. Husam Tayeh (United States Commodity Futures Trading Commission v. Husam Tayeh) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States Commodity Futures Trading Commission v. Husam Tayeh, (11th Cir. 2021).

Opinion

USCA11 Case: 20-11017 Date Filed: 03/02/2021 Page: 1 of 7

[DO NOT PUBLISH]

IN THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT ________________________

No. 20-11017 Non-Argument Calendar ________________________

D.C. Docket No. 1:15-cv-00538-ALB-SRW

UNITED STATES COMMODITY FUTURES TRADING COMMISSION,

Plaintiff-Appellee,

versus

HUSAM TAYEH,

Defendant-Appellant.

________________________

Appeal from the United States District Court for the Middle District of Alabama ________________________

(March 2, 2021)

Before JILL PRYOR, LUCK, and ANDERSON, Circuit Judges.

PER CURIAM: USCA11 Case: 20-11017 Date Filed: 03/02/2021 Page: 2 of 7

Husam Tayeh (“Tayeh”), proceeding pro se, appeals the district court’s final

judgment in favor of the United States Commodity Futures Trading Commission

(the “CFTC”) in its civil action based on violations of the Commodity Exchange

Act 1 (“CEA”). Specifically, he appeals the district court’s calculation of the

disgorgement amount. He also appeals the district court’s order releasing a pallet

of currency held by the FBI to the CFTC as an offset against the final judgment.

I.

On appeal, Tayeh argues that the district court abused its discretion when,

after a bench trial, it failed to deduct his legitimate business expenses from the

amount of disgorgement.

We liberally interpret briefs filed by pro se litigants; however, issues the pro

se litigant fails to brief on appeal are deemed abandoned and are not considered.

Timson v. Sampson, 518 F.3d 870, 874 (11th Cir. 2008). Furthermore, a pro se

litigant also abandons a claim on appeal “when he makes only passing references

to it, or raises it in a perfunctory manner without supporting arguments and

authority.” Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678, 680-81 (11th Cir.

2014).

We review a district court’s calculation of disgorgement for abuse of

discretion. SEC v. Levin, 849 F.3d 995, 1001 (11th Cir. 2017). The CEA

1 Commodity Exchange Act, 7 U.S.C. §§ 1-27f (2018). 2 USCA11 Case: 20-11017 Date Filed: 03/02/2021 Page: 3 of 7

authorizes the CFTC to seek, and district courts to impose, equitable remedies

when a defendant is found to have committed a violation of any of its provisions,

including the “disgorgement of gains received in connection with such violation.”

7 U.S.C. § 13a-1(d)(3)(B). Disgorgement is an equitable remedy intended to

prevent unjust enrichment from ill-gotten gains and must not be used punitively.

CFTC v. Sidoti, 178 F.3d 1132, 1138 (11th Cir. 1999). The CFTC has the burden

to produce a reasonable approximation of a defendant’s ill-gotten gains to sustain a

disgorgement amount. Id.

Once the CFTC meets this burden, “[t]he burden then shifts to the defendant

to demonstrate that [the CFTC’s] estimate is not a reasonable approximation.”

SEC v. Calvo, 378 F.3d 1211, 1217 (11th Cir. 2004). “Exactitude is not a

requirement; so long as the measure of disgorgement is reasonable, any risk of

uncertainty should fall on the wrongdoer whose illegal conduct created that

uncertainty.” Id. (internal quotation marks omitted) (alteration adopted). We have

held that:

where a defendant’s record-keeping or lack thereof has so obscured matters that calculating the exact amount of illicit gains cannot be accomplished without incurring inordinate expense, it is well within the district court’s discretion to rule that the amount of disgorgement will be the more readily measurable proceeds received from the unlawful transactions.

Id. at 1218 (citing CFTC v. Am. Bd. of Trade, Inc., 803 F.2d 1242, 1252 (2d Cir.

1986)). Concerning the issue of deducting business expenses from a disgorgement 3 USCA11 Case: 20-11017 Date Filed: 03/02/2021 Page: 4 of 7

calculation, we have held that “defendants in a disgorgement action are not entitled

to deduct costs associated with committing their illegal acts.” FTC v. Wash. Data

Res., Inc., 704 F.3d 1323, 1325 (11th Cir. 2013) (internal quotation marks

omitted).

In its recent decision, Liu v. SEC, the Supreme Court granted certiorari to

determine “whether § 78u(d)(5) [of the Securities Exchange Act of 1934]

authorized the SEC to seek disgorgement beyond a defendant’s net profits from

wrongdoing.” 140 S. Ct. 1936, 1942 (2020). The Liu Court held that, under

principles of equity, the SEC was precluded from recovering a defendant’s gross

profits and could only recover net profits which accounted for and deducted

legitimate business expenses. Id. at 1949-50 (noting that some of the defendant’s

ill-gotten gains went toward lease payments and cancer-treatment equipment which

“arguably have value independent of fueling a fraudulent scheme”).

Although the district court decision in this case was issued shortly before the

Supreme Court issued its decision in Lui, 2 the district court foresaw the ruling in

Lui:

[T]he Court concludes that the legal issue of whether a disgorgement amount must account for legitimate business expenses is ultimately irrelevant to the disposition of this case. This is so because, even if the law allowed a court to account for a defendant’s business expenses when ordering disgorgement, there would need to be evidence of a defendant’s expenses before a court could account

2 The impact of the Lui decision on this case has been briefed to this Court. 4 USCA11 Case: 20-11017 Date Filed: 03/02/2021 Page: 5 of 7

for them. . . .

Here, Tayeh failed to provide any credible evidence that would allow the Court to consider reducing the stipulated total gain amount with his legitimate business expenses. As noted above, Tayeh’s testimony was not credible. Not to belabor the point, but Tayeh provided only hazy and uncertain estimates of how much he spent on legitimate business transactions. Tayeh testified that he was “not very good at recordkeeping or managing stuff.” (Doc. 218 at 78). He claimed to have had multiple employees, but he could not recall filing any employee-employer tax forms and did not testify about how much he paid them. (Doc. 218 at 96). The CFTC introduced evidence that Tayeh personally withdrew millions in cash from bank accounts and direct-transferred millions more to high-end jewelers. (Doc. 218 at 55–57). Tayeh testified that he used this cash and jewelry to trade for Iraqi dinar in Jordan and Vietnamese dong in Hong Kong. (Doc. 218 at 76). But Tayeh provided nothing—no travel records, government documents, shipping receipts, witness testimony, passport stamps, etc.—to corroborate his testimony about using untraceable cash and jewelry to purchase large amounts of currency overseas.

Dist. Ct. Op., Doc. 227 at 10-11.

Here, the district court did not abuse its discretion when it set the

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Related

Timson v. Sampson
518 F.3d 870 (Eleventh Circuit, 2008)
United States v. Munsey Trust Co.
332 U.S. 234 (Supreme Court, 1947)
Louis Schwartz v. Florida Board of Regents
807 F.2d 901 (Eleventh Circuit, 1987)
Nicholas J. Capuano v. United States
955 F.2d 1427 (Eleventh Circuit, 1992)
Securities and Exchange Commission v. George G. Levin
849 F.3d 995 (Eleventh Circuit, 2017)
Liu v. SEC. & Exch. Comm'n
591 U.S. 71 (Supreme Court, 2020)
Commodity Futures Trading Commission v. Sidoti
178 F.3d 1132 (Eleventh Circuit, 1999)
Securities & Exchange Commission v. Calvo
378 F.3d 1211 (Eleventh Circuit, 2004)

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United States Commodity Futures Trading Commission v. Husam Tayeh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-commodity-futures-trading-commission-v-husam-tayeh-ca11-2021.