United States v. Abdul Inusah

CourtCourt of Appeals for the Fourth Circuit
DecidedMarch 18, 2024
Docket23-4250
StatusUnpublished

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

Bluebook
United States v. Abdul Inusah, (4th Cir. 2024).

Opinion

USCA4 Appeal: 23-4250 Doc: 40 Filed: 03/18/2024 Pg: 1 of 13

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-4250

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

ABDUL INUSAH,

Defendant - Appellant.

Appeal from the United States District Court for the Southern District of West Virginia, at Huntington. Robert C. Chambers, District Judge. (3:21-cr-00070-1)

Submitted: January 10, 2024 Decided: March 18, 2024

Before WYNN, HARRIS, and QUATTLEBAUM, Circuit Judges.

Affirmed by unpublished opinion. Judge Harris wrote the opinion, in which Judges Wynn and Quattlebaum joined.

ON BRIEF: Shawn A. Morgan, STEPTOE & JOHNSON PLLC, Bridgeport, West Virginia, for Appellant. William S. Thompson, United States Attorney, Holly J. Wilson, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, West Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 23-4250 Doc: 40 Filed: 03/18/2024 Pg: 2 of 13

PAMELA HARRIS, Circuit Judge:

A jury convicted Abdul Inusah of multiple charges related to an international

romance fraud scheme. On appeal, Inusah challenges both his conviction and his sentence

of 24 months’ imprisonment. Finding no reversible error, we affirm the judgment of the

district court.

I.

Abdul Inusah moved from Ghana to attend graduate school in West Virginia.

There, he began to act as a middleman in an international romance fraud scheme that

functioned as follows: People in Africa would create false online personas and use them

to offer love and affection to victims. After some invented crisis – the death of a parent,

an emergency medical condition – the victims would be persuaded to send large sums of

money, sometimes adding up to entire life savings, to their false online partners. But

instead, their money went to middlemen or “money mules,” typically in the United States,

who would accept the funds from the victims, keep a percentage as payment for their

involvement, and then forward the rest of the money to the fraudsters abroad.

The role of the middleman was critical to the scheme’s success. Large wire transfers

to African countries can raise concerns at United States banks. By instructing victims to

send money instead to domestic middlemen, the fraudsters sought to avoid suspicion. And

by maintaining multiple accounts and quickly moving victims’ money from account to

account, the middlemen sought to avoid fraud detection measures and frozen or closed

bank accounts.

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A.

A federal grand jury in the Southern District of West Virginia indicted Inusah on

multiple counts for his role in the scheme, including wire fraud, see 18 U.S.C. § 1343;

receipt of stolen property, see 18 U.S.C. § 2315; and conspiracy to commit money

laundering, see 18 U.S.C. § 1956(h). During a four-day jury trial, the government

presented testimony from six victims and from a government financial analyst who

summarized bank records showing transfers from the victims to Inusah’s multiple

accounts. The government also called three of Inusah’s fellow middlemen, 1 who testified

to Inusah’s role in the scheme and his knowledge of its unlawful nature.

At the end of the government’s case-in-chief, Inusah moved for a Rule 29 judgment

of acquittal, see Fed. R. Crim. P. 29, arguing that the government had not proven that he

had the requisite intent to defraud or knowledge of the fraudulent scheme. The district

court denied the motion:

[The government has] produced direct evidence from the testimony of co- conspirators that Mr. Inusah knew, as they did, that this money was coming as a result of a fraudulent scheme. . . .

The government has demonstrated that very substantial deposits were made into Mr. Inusah’s account, in his name . . . . The evidence is that the money originated from the victims of the fraud. They testified as to that. There were substantial amounts of money. The money was then handled by the defendant in a manner consistent with the testimony of the co-conspirators, that they attempted to do relatively rapid transactions, use multiple bank accounts, move the money among and through these various accounts as quickly as possible and keep some of it. And so I think all of that is sufficient

1 The other middlemen – Kenneth Emeni, John Nassy, and Kenneth Ogudu – were charged separately, pleaded guilty, and agreed to cooperate with the government.

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to show the defendant’s knowledge and intent with respect to each of the counts.

J.A. 446-47.

Inusah then testified on his own behalf, contending that he was unaware that the

tens of thousands of dollars deposited into his accounts were fraudulently obtained; instead,

he said, he believed he was simply doing favors for Ghanaian acquaintances attempting to

purchase cars. The next day, the jury convicted Inusah on four counts: two counts of wire

fraud, one count of receipt of stolen money, and one count of conspiracy to launder money. 2

B.

Before Inusah’s sentencing, the probation office prepared a presentence

investigation report calculating an advisory sentencing range of 30 to 37 months’

imprisonment. That range was based on an offense level of 19, which reflected a 10-level

enhancement under U.S.S.G. § 2B1.1 for a total loss amount of more than $150,000 but

not more than $250,000. Inusah objected to the loss calculation on multiple grounds.

At sentencing, the district court found that the government had provided sufficiently

reliable evidence of loss and adequately supported a total loss amount of $152,000. The

court rejected Inusah’s argument that a $20,000 deposit into one of his bank accounts

should be excluded because the government had not established “venue” by proving the

account was in the Southern District of West Virginia. J.A. 825-26 (explaining that there

2 The jury acquitted Inusah of two counts of unlawful monetary transactions, see 18 U.S.C. § 1957, and one charge of aggravated identity theft, see 18 U.S.C. § 1028A, in connection with his creation of a bank account in the name of his ex-girlfriend.

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is no venue requirement for loss amounts at sentencing). And the court also denied

Inusah’s objection to including $24,000 in funds related to conduct for which he was

acquitted, citing the “current state of the [G]uidelines and the law.” J.A. 822.

That left the district court with the same offense level of 19 and Guidelines range of

30 to 37 months calculated by the PSR. But the court, noting challenges to the use of

acquitted conduct at sentencing, used its discretion to vary downward as if the $24,000 in

loss from acquitted conduct had been excluded. This “prophylactic exercise,” J.A. 823,

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