United States v. Bifulco

127 F. App'x 548
CourtCourt of Appeals for the Second Circuit
DecidedApril 11, 2005
DocketNo. 03-1485
StatusPublished
Cited by1 cases

This text of 127 F. App'x 548 (United States v. Bifulco) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second 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. Bifulco, 127 F. App'x 548 (2d Cir. 2005).

Opinion

SUMMARY ORDER

UPON DUE CONSIDERATION of this appeal from the United States District [549]*549Court for the Western District of New York (Arcara, C.J.), it is hereby ORDERED, ADJUDGED, AND DECREED that the judgment of the district court is AFFIRMED.

Defendant-Appellant Frank J. Bifulco appeals the judgment imposed in the United States District Court for the Western District of New York, following a jury verdict convicting him of conspiracy to commit mail and wire fraud in violation of 18 U.S.C. § 371; wire fraud in violation of 18 U.S.C. § 1343 and § 2(b); mail fraud in violation of 18 U.S.C. § 1341 and § 2(b); and use of fire to commit a federal felony in violation of 18 U.S.C. § 844(h)(1) and § 2(b). The district court sentenced Bifulco principally to a term of imprisonment of 130 months. On appeal, Bifulco argues that the evidence of his specific intent to defraud Allstate Insurance Company (“Allstate”) was insufficient to support his conviction on these four counts.1 We assume familiarity by the parties with the facts and procedural history of the case.

Although we review de novo a district court’s decision regarding the sufficiency of evidence for conviction, a defendant challenging a conviction on the basis of evidentiary insufficiency “bears a heavy burden.” United States v. Henry, 325 F.3d 93, 103 (2d Cir.2003). When reviewing the sufficiency of evidence forming the basis for a conviction, “this Court will view the evidence in the light most favorable to the government, and eonstru[e] all permissible inferences in its favor.” United States v. Reyes, 157 F.3d 949, 955 (2d Cir.1998) (alteration in original) (internal quotations omitted). A jury’s verdict must be upheld if “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979); see also United States v. Morrison, 153 F.3d 34, 49 (2d Cir.1998).

The mail fraud statute, codified at 18 U.S.C. § 1341, prohibits in relevant part the use of the mails in furtherance of “any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises.” Interpreting this statutory language, this Court has established a three-prong test for a mad fraud conviction: the government must prove “(1) use of the mails to further (2) a scheme to defraud with (3) money or property as the object of the scheme.” United States v. Kinney, 211 F.3d 13, 17 (2d Cir.2000) (internal quotation marks omitted). The wire fraud statute, codified at 18 U.S.C. § 1343, contains a parallel provision to § 1341. Section 1343 prohibits in relevant part the use of interstate wires in furtherance of “any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises.” This Court’s interpretation of § 1343 draws from its reading of § 1341. To establish a defendant’s violation of the wire fraud statute, the government must prove “the existence of a scheme to defraud, that money or property were the object of the scheme, and that [the] defendant used interstate wires in furtherance of that scheme.” United States v. Guadagna, 183 F.3d 122, 129 (2d Cir.1999).

Only the “scheme to defraud” elements of §§ 1341 and 1343 are implicated by Bifulco’s appeal. “Critical to a showing of a scheme to defraud [under the mail and [550]*550wire fraud statutes] is proof that [the] defendants possessed a fraudulent intent.” United States v. Starr, 816 F.2d 94, 98 (2d Cir.1987). While the government does not have to prove that the scheme to defraud caused actual injury, “it must ... prove that defendants contemplated some actual harm or injury to their victims. Only a showing of intended harm will satisfy the element of fraudulent intent.” Id. Starr emphasized the importance of this intent requirement to a mail or wire fraud conviction, observing that “Misrepresentations amounting only to a deceit are insufficient to maintain a mail or wire fraud prosecution. Instead, the deceit must be coupled with a contemplated harm to the victim.” Id. Similarly, “[i]t is not sufficient that [the] defendant realizes that the scheme is fraudulent and that it has the capacity to cause harm to its victims.” Guadagna, 183 F.3d at 129; see also United States v. Gabriel, 125 F.3d 89, 96-97 (2d Cir.1997) (holding that “some realization” that a scheme may be fraudulent and potentially harmful does not alone automatically satisfy the “intent to harm” requirement of the mail fraud and wire fraud statutes); United States v. Dinome, 86 F.3d 277, 283 (2d Cir.1996) (holding that the government must prove defendant’s intent to harm for a § 1341 or § 1343 conviction).

Bifulco asserts that insufficient evidence exists of his specific intent to defraud Allstate to support his convictions for wire or mail fraud. We agree with Bifulco that no direct proof exists that Bifulco intended to harm Allstate by filing a false insurance claim for Elizabeth Tata’s destroyed Nissan. While Angelo Albert testified that he aimed to destroy the car so that he could file a false insurance claim for it, neither Albert nor Tata ever told Bifulco of their intentions to file a false insurance claim for the burned vehicle. Nor did Tata testify that Bifulco participated in her conversations with Albert about filing a false insurance claim.

Instead, Bifulco was only told that Tata had driven the car in excess of the mileage permitted by her lease. Bifulco also knew that Tata wished to use illicit methods— such as rolling back the odometer — to avoid paying for the excess mileage. Ample evidence supports the proposition that Albert and Bifulco collaborated to destroy Tata’s car by arson so that Tata would not incur additional mileage charges.

The question we must resolve, then, is whether the jury could have inferred Bifulco’s specific intent to defraud Allstate— even in the absence of direct proof of this specific intent — from Bifulco’s awareness of Tata’s motivation for destroying the Nissan. We believe that the jury could have done so.

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Bluebook (online)
127 F. App'x 548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-bifulco-ca2-2005.