United States v. De Souza Prado

142 F.4th 99
CourtCourt of Appeals for the First Circuit
DecidedJuly 2, 2025
Docket24-1011
StatusPublished

This text of 142 F.4th 99 (United States v. De Souza Prado) is published on Counsel Stack Legal Research, covering Court of Appeals for the First 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. De Souza Prado, 142 F.4th 99 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1011

UNITED STATES OF AMERICA,

Appellee,

v.

THIAGO DE SOUZA PRADO,

Defendant, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Mark L. Wolf, U.S. District Judge]

Before

Montecalvo, Kayatta, and Aframe, Circuit Judges.

James M. Mason, with whom Handelman & Mason LLC was on brief, for appellant. Lauren S. Zurier, Assistant United States Attorney, with whom Zachary A. Cunha, U.S. Attorney, was on brief, for appellee.

July 2, 2025 AFRAME, Circuit Judge. A jury convicted Thiago de Souza

Prado of wire fraud, conspiracy to commit wire fraud, and

aggravated identity theft. The convictions arose from a scheme to

defraud rideshare and food delivery companies and, to further that

scheme, steal or misappropriate the identities of third parties.

The district court sentenced Prado to seventy months in prison.

Prado appeals, challenging his convictions and sentence. We

affirm.

I.

The following facts are uncontested. Prado was born in

Brazil. In 2003, Prado entered the United States on a tourist

visa, but he is not presently authorized to be in the country. In

January 2019, Prado began participating in the criminal scheme for

which he was convicted. A network of Brazilian nationals living

in the United States carried out the scheme by creating and using

fraudulent accounts so as to permit ineligible individuals to drive

for Uber, Uber Eats, Lyft, DoorDash, Instacart, and Grubhub. Prado

was himself ineligible to drive for these companies because he had

numerous disqualifying driving infractions; others were ineligible

because, among other reasons, they were not legally authorized to

work.

Prado initially drove under fraudulent accounts created

by others and paid rental fees to use these accounts. Eventually,

however, Prado began creating fraudulent accounts to use himself

- 2 - and to rent to others. To establish these accounts, Prado

surreptitiously obtained driver's license images and Social

Security numbers from individuals who could pass the necessary

driver background checks. Prado acquired these images and numbers

from several sources: an associate who worked at a night club and

took pictures of patrons' licenses; employee records from a

painting company that he once owned; an associate who acquired

Social Security numbers from the dark web; software Prado purchased

that enabled him to access the dark web and acquire Social Security

numbers himself; and associates who delivered alcohol for grocery

delivery companies and took photographs of patrons' licenses,

purportedly to confirm their ages.

Prado also used a different software program, called a

"drone" or "bot," to defraud Uber and Lyft. The program spoofed

GPS information on the companies' apps to make it appear that the

fake drivers on Prado's fraudulent accounts had completed rides

that they never actually provided. The program also made completed

trips look longer than they had been, thus inflating driver fees.

Prado bought the drone program, shared it with other participants

in the scheme, and sold it to other drivers for hundreds of

dollars.

Finally, Prado defrauded Uber and Lyft by having the

fake accounts he created refer other fake accounts as "new"

drivers. These fake referrals generated for Prado hundreds of

- 3 - dollars in rewards paid by Uber and Lyft for referring new drivers.

Prado also used an account in his wife's name to receive the

referral rewards.

On May 17, 2021, a grand jury indicted Prado and

seventeen others in connection with the scheme described above.

Over two years later, the grand jury returned a third superseding

indictment charging Prado with one count of conspiracy to commit

wire fraud, 18 U.S.C. § 1349 (Count One); three counts of wire

fraud, 18 U.S.C. § 1343 (Counts Two to Four); and three counts of

aggravated identity theft, 18 U.S.C. § 1028A (Counts Five to

Seven). Only Prado went to trial. After a seven-day trial, a

jury convicted him on all counts. The district court later

sentenced Prado to concurrent forty-six-month prison terms on

Counts One through Four and concurrent twenty-four-month prison

terms on Counts Five through Seven to run consecutively, thereby

producing a total term of seventy months in prison.

II.

Prado challenges his convictions by asserting that he

was prejudiced by an amendment of the third superseding indictment

during trial and by the district court's refusal to disqualify the

prosecution team from involvement in his case. Alternatively,

Prado contends that his sentence was procedurally and

substantively unreasonable.

- 4 - A.

We first address Prado's prejudicial amendment argument.

The third superseding indictment detailed how and when Prado

defrauded some of his victims and misappropriated and misused

others' identities. In so doing, the document's narrative section

employed generic pseudonyms (for example, "Rideshare Company A" or

"Victim 1"), rather than the corporate or individual victims'

names. On the fourth day of trial, the district court suggested

that the government submit a revised version of the third

superseding indictment replacing the pseudonyms with the victims'

names. The government did so shortly thereafter. The court took

this action to assist the jury deliberations by making the

indictment more intelligible.

Days later, following the close of evidence, Prado

raised a pro se objection that he had not received notice of the

names of the victims referenced in the third superseding indictment

until the district court allowed the document's revision

mid-trial, despite having asked his attorney for these names.

Defense counsel did not join in the objection and confirmed that,

in the months prior to trial, the prosecution had twice provided

him with the victims' names. Defense counsel also confirmed that

he knew the names of the victims identified in each count. The

court took the matter under advisement.

- 5 - Following the verdict, the district court allowed Prado

to pursue his lack-of-notice objection by means of a pro se motion.

Prado responded with a motion for acquittal under Federal Rule of

Criminal Procedure 29 and an affidavit reasserting that, despite

having sought the information from his attorney, he did not learn

the victims' names until the sixth day of trial. Prado argued

that this late notice violated his right to a constitutionally

adequate indictment. Prado further argued that this violation was

structural error requiring the court to set aside the jury's

verdicts and dismiss the indictment.

By a written memorandum and order, the district court

denied the motion. After noting that Prado's challenge to the

unrevised third superseding indictment should have been brought as

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142 F.4th 99, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-de-souza-prado-ca1-2025.