United States v. Alpesh Patel

Court of Appeals for the Eleventh Circuit·Decided September 10, 2026·No. 25-14031·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 25-14031

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

ALPESH PATEL, Defendant-Appellant.

Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:21-cr-00451-WMR-JKL-5

Before LUCK, MARCUS, and WILSON, Circuit Judges. PER CURIAM:

Alpesh Patel appeals his convictions and 37-month sentence for conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349 (Count One); conspiracy to commit money laundering, in

2 Opinion of the Court 25-14031

violation of 18 U.S.C. § 1956(h) (Count Two); and money laundering , in violation of 18 U.S.C. §§ 1957 and 2 (Counts Three and Four). On appeal, Patel argues that: (1) the district court erred in denying his motion for judgment of acquittal because the evidence was insufficient to sustain his convictions; (2) his sentence was procedurally unreasonable because the district court erroneously refused to apply a minor-role reduction under U.S.S.G. § 3B1.2(b); (3) his sentence was procedurally unreasonable because the district court erroneously applied a two-level enhancement for obstruction of justice under U.S.S.G. § 3C1.1; and (4) his sentence was substantively unreasonable. After careful review, we affirm.

I.

Where the defendant properly preserves a motion for judgment of acquittal, we will conduct a de novo review of the sufficiency of the evidence. United States v. Jiminez, 564 F.3d 1280, 1284 (11th Cir. 2009). Where a defendant moves for acquittal at the close of the government’s case, the defendant may preserve the claim by renewing the motion for judgment of acquittal at the close of the evidence. United States v. Bichsel, 156 F.3d 1148, 1150 (11th Cir. 1998) (per curiam).

The district court’s determination of the defendant’s role in the criminal offense is a finding of fact we review for clear error. United States v. De Varon, 175 F.3d 930, 937 (11th Cir. 1999) (en banc); see United States v. Cabezas-Montano, 949 F.3d 567, 608 (11th Cir. 2020) (holding that the district court did not clearly err in deny-

25-14031 Opinion of the Court 3

ing the defendants minor-role reductions). When reviewing a district court’s decision to apply an enhancement under § 3C1.1, we review factual findings for clear error and the district court’s application of the Guidelines to those facts de novo. United States v. Guevara , 894 F.3d 1301, 1311 (11th Cir. 2018). We review the sentence a district court imposes for “reasonableness,” which “merely asks whether the trial court abused its discretion.” United States v. Pugh, 515 F.3d 1179, 1189 (11th Cir. 2008) (citation modified).

II.

First, we are unpersuaded by Patel’s claim that the district court erred in denying his motion for a judgment of acquittal because the evidence produced at trial was insufficient to prove the knowledge element of his offenses. The district court’s denial of “motions for judgment of acquittal will be upheld if a reasonable trier of fact could conclude that the evidence establishes the defendant ’s guilt beyond a reasonable doubt.” United States v. Rodriguez , 218 F.3d 1243, 1244 (11th Cir. 2000) (per curiam). However, we must view the facts, and draw all reasonable inferences therefrom , in the light most favorable to the government. United States v. Hansen, 262 F.3d 1217, 1236 (11th Cir. 2001) (per curiam).

When a reasonable trier of fact could find that the evidence established guilt beyond a reasonable doubt, “[i]t is not necessary that the evidence exclude every reasonable hypothesis of innocence or be wholly inconsistent with every conclusion except that of guilt . . . . A jury is free to choose among the constructions of the evidence.” United States v. Calderon, 127 F.3d 1314, 1324 (11th

4 Opinion of the Court 25-14031

Cir. 1997) (citation modified). Thus, we must sustain a verdict where “there is a reasonable basis in the record for it.” United States v. Farley, 607 F.3d 1294, 1333 (11th Cir. 2010) (citation modified).

In deciding whether the evidence was sufficient, we do not distinguish between circumstantial and direct evidence. United States v. Tate, 586 F.3d 936, 945 (11th Cir. 2009). “Circumstantial evidence can be and frequently is more than sufficient to establish guilt beyond a reasonable doubt.” United States v. Henderson, 693 F.2d 1028, 1030 (11th Cir. 1982). “[C]ircumstantial evidence is not testimony to the specific fact being asserted, but testimony to other facts and circumstances from which the jury may infer that the fact being asserted does or does not exist.” Id. at 1031. The jury must decide whether to draw the inference between the evidence presented and the fact asserted. Id. “Where the government relies on circumstantial evidence, reasonable inferences, and not mere speculation , must support the jury’s verdict.” United States v. Isnadin, 742 F.3d 1278, 1303 (11th Cir. 2014) (citation modified).

Where an appellant’s “argument depends upon challenges to the credibility of witnesses, the jury has exclusive province over that determination[,] and the court of appeals may not revisit this question” unless the testimony is “incredible as a matter of law.” United States v. Chastain, 198 F.3d 1338, 1351 (11th Cir. 1999). In conducting sufficiency review, we will not consider testimony incredible as a matter of law unless it cannot, on its face, be believed, like where the witness could not have observed certain events or they are contrary to the laws of nature. United States v. Thompson,

25-14031 Opinion of the Court 5

422 F.3d 1285, 1291 (11th Cir. 2005). We’ve held that a jury is free to infer that a testifying defendant is not telling the truth by his demeanor , and “a statement by a defendant, if disbelieved by the jury, may be considered as substantive evidence of the defendant’s guilt when combined with other evidence.” United States v. Pon, 963 F.3d 1207, 1234 (11th Cir. 2020) (citation modified).

To convict a defendant for conspiracy to commit wire fraud under § 1349, the government must prove: “(1) a conspiracy to commit [wire fraud]; (2) knowledge of the conspiracy; and (3) that individual knowingly and voluntarily joined the conspiracy.” United States v. Gonzalez, 834 F.3d 1206, 1220 (11th Cir. 2016). To convict a defendant for conspiracy to commit money laundering under § 1956(h), it must prove: “(1) agreement between two or more persons to commit a money-laundering offense; and (2) knowing and voluntary participation in that agreement by the defendant .” United States v. Broughton, 689 F.3d 1260, 1280 (11th Cir. 2012). Finally, to convict a defendant for money laundering under § 1957, it must prove that the defendant knowingly engaged or attempted to engage in a monetary transaction in criminally derived property that is of value greater than $10,000 and is derived from specified unlawful activity. 18 U.S.C. § 1957(a).

Here, Patel’s convictions arose out of a conspiracy to defraud that involved calling victims over the telephone and convincing them to send money to the defendants through various scare tactics. For example, “the person on the telephone purported to be a United States government official and told the victims that they

6 Opinion of the Court 25-14031

were suspected of either criminal conduct or were the victims of identity theft and were in danger of losing their life savings.” Patel and co-conspirator Vikas Mehta “provided bank account information for bank accounts they controlled to their co-conspirators in the United States and India” so that defrauded victims could be instructed to wire funds into those accounts.

Free access — add to your briefcase to read the full text and ask questions with AI

United States v. Alpesh Patel, (11th Cir. 2026).

United States v. Alpesh Patel (United States v. Alpesh Patel) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

United States v. Chastain
198 F.3d 1338 (Eleventh Circuit, 1999)
United States v. Christian A. Hansen
262 F.3d 1217 (Eleventh Circuit, 2001)
United States v. Michael Donyell Boyd
291 F.3d 1274 (Eleventh Circuit, 2002)
United States v. Ram Kumar Singh
291 F.3d 756 (Eleventh Circuit, 2002)
United States v. Williams
340 F.3d 1231 (Eleventh Circuit, 2003)
United States v. Elizabeth Marie Morse Thompson
422 F.3d 1285 (Eleventh Circuit, 2005)
United States v. Pugh
515 F.3d 1179 (Eleventh Circuit, 2008)
United States v. Jiminez
564 F.3d 1280 (Eleventh Circuit, 2009)
United States v. Docampo
573 F.3d 1091 (Eleventh Circuit, 2009)
United States v. Tate
586 F.3d 936 (Eleventh Circuit, 2009)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Brenton-Farley
607 F.3d 1294 (Eleventh Circuit, 2010)
United States v. Tome
611 F.3d 1371 (Eleventh Circuit, 2010)
United States v. Irey
612 F.3d 1160 (Eleventh Circuit, 2010)
United States v. Clarence Henderson
693 F.2d 1028 (Eleventh Circuit, 1982)
United States v. Jayyousi
657 F.3d 1085 (Eleventh Circuit, 2011)
United States v. Alberto Calderon
127 F.3d 1314 (Eleventh Circuit, 1997)
United States v. Isabel Rodriguez De Varon
175 F.3d 930 (Eleventh Circuit, 1999)
United States v. Richard William Peterson
689 F.3d 1260 (Eleventh Circuit, 2012)
United States v. Daniel McKinley
732 F.3d 1291 (Eleventh Circuit, 2013)