United States v. Cunningham

CourtCourt of Appeals for the Tenth Circuit
DecidedNovember 12, 2025
Docket24-3059
StatusPublished

This text of United States v. Cunningham (United States v. Cunningham) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Cunningham, (10th Cir. 2025).

Opinion

Appellate Case: 24-3059 Document: 62-1 Date Filed: 11/12/2025 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS November 12, 2025 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-3059

MONTRESSA CUNNINGHAM,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the District of Kansas (D.C. No. 5:21-CR-40105-TC-1) _________________________________

Paige A. Nichols, Former Assistant Federal Public Defender (Melody Brannon, Federal Public Defender, with her on the briefs), Kansas Federal Public Defender, Topeka, Kansas, for Defendant-Appellant.

James A. Brown (Kate E. Brubacher, United States Attorney, and Carrie N. Capwell, Assistant United States Attorney, on the brief), District of Kansas, Kansas City, Kansas, for Plaintiff-Appellee. _________________________________

Before MATHESON, EBEL, and MORITZ, Circuit Judges. _________________________________

EBEL, Circuit Judge. _________________________________

A jury convicted Defendant Montressa Cunningham (“Cunningham”) of

sixteen offenses stemming from a fourteen-month fraudulent scheme. Cunningham

and his wife Felicia purchased seven higher-end used cars, financing those purchases Appellate Case: 24-3059 Document: 62-1 Date Filed: 11/12/2025 Page: 2

with bank loans they obtained through the car dealerships. Cunningham and his wife

obtained those bank loans by providing false information on their loan applications.

Before registering the cars, the Cunninghams altered the title paperwork they

received from the car dealerships to eliminate the bank lender’s lien information.

That enabled the Cunninghams to obtain a false clear title to each vehicle, which they

then used to obtain cash, either by selling the car or obtaining a title loan on the

vehicle. In this direct criminal appeal, Cunningham challenges the sufficiency of the

evidence to support seven of his sixteen convictions. Specifically, Cunningham

challenges his bank fraud conviction on Count 2, his wire fraud conviction on Count

9, and his money laundering convictions on Counts 12 through 16. Having

jurisdiction under 28 U.S.C. § 1291, we REVERSE his bank fraud conviction on

Count 2 because there was no evidence that Cunningham was involved in his wife

obtaining the bank loan underlying this count. We also REVERSE Cunningham’s

wire fraud conviction on Count 9 because the Government failed to prove the

requisite interstate-commerce element of that offense. But we AFFIRM

Cunningham’s money laundering convictions on Counts 12 through 16. We

REMAND for resentencing.

I. BACKGROUND

The United States originally indicted both Cunningham and Felicia on

seventeen counts charging conspiracy, bank fraud, wire fraud, and money laundering.

The district court severed the counts against Felicia after she informed the court that

she intended to testify at trial against Cunningham in exchange for the United States

2 Appellate Case: 24-3059 Document: 62-1 Date Filed: 11/12/2025 Page: 3

dismissing all charges against her. Cunningham, in turn, sought to prevent his wife’s

testimony against him by asserting marital privilege. The United States ultimately

did not call Felicia to testify at Cunningham’s trial.

At trial, the Government dismissed Count 12 and renumbered the counts. The

district court then tried Cunningham on the following counts:

Count 1 ‒ charging Cunningham with conspiring (18 U.S.C. § 1349) with Felicia, from on or about December 3, 2018, through on or about February 3, 2020, to commit bank fraud (18 U.S.C. § 1344) and wire fraud (18 U.S.C. § 1343);

Counts 2‒8 ‒ charging bank fraud and aiding and abetting bank fraud (18 U.S.C. §§ 2, 1344), one count for each of the seven used cars that the Cunninghams financed with bank loans 1;

Counts 9‒11 ‒ charging wire fraud and aiding and abetting wire fraud (18 U.S.C. §§ 2, 1343), based on use of the Internet either to purchase cars or to apply for loans; and

Counts 12‒16 ‒ charging money laundering and aiding and abetting money laundering (18 U.S.C. §§ 2, 1956(a)(1)(B)(i)) the proceeds of their illegal activity by either selling the cars or using the car titles to obtain title loans.

Summarizing, the evidence at trial, viewed in the light most favorable to the

verdict, United States v. Little, 119 F.4th 750, 786 (10th Cir. 2024), cert. denied,

2025 WL 2824198 (U.S. Oct. 6, 2025), indicated the following: Cunningham and

Felicia lived in Junction City, Kansas. Over the course of more than a year,

1 The victims of these bank fraud counts, as charged, were the banks that loaned the Cunninghams money to buy each of the seven used cars. Those bank fraud offenses were complete when the Cunninghams knowingly provided the banks with “materially false information in order to induce the loan[s].” United States v. Hollis, 971 F.2d 1441, 1452 (10th Cir. 1992). While the Cunninghams also committed fraud by altering the titles and defrauded the title loan companies, those fraudulent acts were not charged as separate offenses.

3 Appellate Case: 24-3059 Document: 62-1 Date Filed: 11/12/2025 Page: 4

beginning in December 2018, the Cunninghams purchased seven higher-end used

cars from several different Kansas car dealers, financing those purchases with

fraudulently obtained bank loans arranged through the car dealerships. The

Cunninghams made few to no payments on any of these car loans. Before registering

the vehicles in either Georgia or Kansas, the Cunninghams altered the title paperwork

to remove information identifying the bank lenders as the vehicles’ lienholders,

enabling the Cunninghams falsely to obtain clear title to the vehicles. They then used

those false clear titles to sell two of the vehicles and to use the other five vehicles as

collateral for title loans. 2

After a six-day trial, the jury convicted Cunningham of all sixteen counts. The

district court imposed concurrent forty-six-month prison sentences for each of the

sixteen convictions. After Cunningham was sentenced, the United States dismissed

all charges against Felicia. On appeal, Cunningham argues there was insufficient

evidence to support seven of his sixteen convictions. 3

2 The Cunninghams never paid any money when they bought a car. They instead financed the transactions with the fraudulently obtained bank loans, based on misrepresentations of their financial condition.

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