United States v. Barama

CourtCourt of Appeals for the Ninth Circuit
DecidedJanuary 27, 2025
Docket23-2087
StatusUnpublished

This text of United States v. Barama (United States v. Barama) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth 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. Barama, (9th Cir. 2025).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JAN 27 2025 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA No. 23-2087 D.C. No. Plaintiff - Appellee, 3:19-cr-00463-RS-2 v. MEMORANDUM* SIVANNARAYANA BARAMA,

Defendant - Appellant.

Appeal from the United States District Court for the Northern District of California Richard Seeborg, Chief District Judge, Presiding

Argued and Submitted December 2, 2024 San Francisco, California

Before: M. SMITH, MILLER, and BUMATAY, Circuit Judges.

Defendant Sivannarayana Barama appeals his convictions and sentence on

four counts of securities fraud in violation of 18 U.S.C. § 1348(2). We have

jurisdiction under 28 U.S.C. § 1291, and we affirm Barama’s convictions.

However, we vacate his sentence and remand for resentencing.

Because the parties are familiar with the facts and background of this case,

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. we provide only information necessary to our ruling. In 2016, Barama reached out

to Janardhan Nellore, his former coworker at Palo Alto Networks, Inc. (PANW),

about trading PANW securities. Through his role at PANW, Nellore had access to

confidential PANW revenue information. Nellore later testified that he provided

trading advice to Barama based on this confidential information. Nellore

messaged Barama details like “strong numbers expected,” referring to PANW’s

non-public revenue information.

Although Nellore and Barama only ever discussed Barama’s investing small

amounts, such as a few thousand dollars, Barama invested significantly more, and

his “huge trades” in PANW eventually alerted the FBI. Nellore later pleaded

guilty to one count of conspiracy to commit securities fraud in violation of 18

U.S.C. § 1349. Barama proceeded to trial on one count of conspiracy to commit

securities fraud in violation of 18 U.S.C. § 1349 and four counts of securities fraud

and aiding and abetting in violation of 18 U.S.C. §§ 1348 and 2. A jury later

acquitted Barama of the conspiracy charge but convicted him on the four counts of

securities fraud under §1348(2). Barama timely appealed.

1. On appeal, Barama first argues that there was insufficient evidence to

convict him under § 1348(2). While the jury had the option to convict Barama

under either § 1348(1) or § 1348(2), it opted to convict him only under § 1348(2),

which requires that money or property be obtained “by means of false or fraudulent

2 24-6 pretenses, representations, or promises.” 18 U.S.C. § 1348(2). Barama argues that

the government did not prove that money or property was obtained by false

pretenses, false statements, or false promises.

“We review de novo whether sufficient evidence supports a conviction.”

United States v. Liew, 856 F.3d 585, 596 (9th Cir. 2017). There is sufficient

evidence “if, viewing the evidence in the light most favorable to the prosecution,

any rational trier of fact could have found the essential elements of the crime

beyond a reasonable doubt.” United States v. Phillips, 929 F.3d 1120, 1123 (9th

Cir. 2019).

Here, the government provided evidence that Barama lied to Nellore about

the size of his trades by understating his trading volume. For example, in a series

of text messages sent in August 2016, which predated the trades at issue in the

indictment, Nellore told Barama to buy “sept 16 dated calls only for 3 to 4k,” and

when Nellore asked Barama how many call options he had bought, Barama said

five. Nellore understood Barama to be buying five call options for a total

investment of $3,000 to $4,000. Instead, following his text to Nellore, Barama

bought thirty call options set to expire on September 16 for a total cost of $24,300.

Given Nellore’s care to disguise his own fraudulent activity, a rational trier of fact

could have found that Nellore provided Barama with PANW’s confidential

revenue information only because he believed Barama’s lies about the size of his

3 24-6 trades.

Alternatively, Barama’s convictions can be sustained under an aiding and

abetting theory. The government provided evidence that Barama sought out

Nellore for information on PANW securities and continued to seek out that

information despite evidence suggesting he knew Nellore was violating PANW’s

confidentiality policies, thereby making a false promise. Therefore, a rational juror

could have found that Barama “induced” or “procured” Nellore to commit fraud, as

required for conviction under the standard aiding and abetting instructions

provided to the jury.

2. Barama also argues that the district court plainly erred by constructively

amending the indictment to allow for a conviction based on omitted facts.

Although the indictment did not include an omissions theory, the jury instructions

stated that, to find Barama guilty under § 1348(2), the government had to prove

beyond a reasonable doubt that Barama obtained money or property “by means of

materially false or fraudulent pretenses, representations, promises, or omitted

facts.”

The government and Barama dispute whether Barama merely forfeited this

argument, meaning our court could review it for plain error, or waived it, meaning

our court should deny review under the invited error doctrine. See United States v.

Baldwin, 987 F.2d 1432, 1437 (9th Cir. 1993). Regardless, Barama has not

4 24-6 demonstrated that he deserves reversal even under plain error review. To establish

plain error, Barama must show that “(1) there was an error, (2) the error is clear or

obvious, (3) the error affected his substantial rights, and (4) the error seriously

affected the fairness, integrity, or public reputation of judicial proceedings.”

United States v. Johnson, 979 F.3d 632, 636 (9th Cir. 2020).

Barama argues that because there was evidence that he omitted facts as to

his trading volume, a jury could have concluded that those omissions provided the

basis for his securities fraud convictions. But the government never presented an

omissions theory to the jury. To the extent that the government presented evidence

about Barama’s trading volume, it was in the context of Barama’s affirmative lies

about his trading volume. Therefore, the evidence at trial overwhelmingly

supported conviction based on Barama’s lies or Nellore’s misrepresentations, not

omitted facts. As such, Barama has failed to show that any error by the district

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