United States v. Dimitar Petlechkov

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 19, 2022
Docket21-5199
StatusUnpublished

This text of United States v. Dimitar Petlechkov (United States v. Dimitar Petlechkov) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Dimitar Petlechkov, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0031n.06

Case Nos. 21-5174/5199

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 19, 2022 ) DEBORAH S. HUNT, Clerk UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF DIMITAR PETLECHKOV, ) TENNESSEE Defendant-Appellant. ) )

Before: SUHRHEINRICH, THAPAR, and LARSEN, Circuit Judges.

THAPAR, Circuit Judge. This is Dimitar Petlechkov’s second appeal from a criminal

judgment against him for mail fraud. He raises five issues. We affirm.

I.

FedEx gives high-volume customers shipping discounts. Dimitar Petlechkov (a native of

Bulgaria) wanted access to those discounts. So he called FedEx, claiming to be a vendor for one

of their high-volume shippers, General Dynamics. After FedEx linked his account to the General

Dynamics account, Petlechkov “used those discounted rates to offer shipping services to third

parties, pocketing the profit margin between what he charged the third parties and what he paid

FedEx.” United States v. Petlechkov, 922 F.3d 762, 766 (6th Cir. 2019). This went on for roughly

five years. During that time, Petlechkov shipped over 63,000 packages.

In 2014, FedEx uncovered the scheme, and the government charged Petlechkov with

twenty counts of mail fraud. See 18 U.S.C. § 1341. A jury convicted him on all twenty counts. Case Nos. 21-5174/5199, United States v. Petlechkov

The district court sentenced Petlechkov to thirty-seven months in prison and ordered him to pay

FedEx $801,219.02 in restitution. The district court also included a preliminary forfeiture order

with a money judgment of $367,099.62. The preliminary forfeiture order listed three parcels of

property as forfeitable substitute assets (in case the money judgment could not be collected).

Petlechkov appealed his convictions, sentence, and restitution award. We vacated Petlechkov’s

convictions on seventeen counts, affirmed his convictions on three, and remanded on his sentence

and restitution award. See Petlechkov, 922 F.3d at 771.

On remand, the district court again sentenced Petlechkov to thirty-seven months in prison.

And it imposed the same restitution award—$801,219.02—and the same preliminary forfeiture

order. This time, however, the court also imposed a two-year term of supervised release.

Petlechkov moved to vacate the preliminary forfeiture order and moved for a new trial. The court

denied both motions, and Petlechkov appealed.

II.

Petlechkov raises five issues on appeal. He argues that the district court erred in:

(1) denying his motion for a new trial based on newly discovered evidence; (2) determining the

loss amount; (3) determining the restitution amount; (4) denying his motion to vacate the

preliminary forfeiture order; and (5) imposing a two-year term of supervised release. We take

each in turn.

A.

We first consider whether the district court erred in denying Petlechkov’s motion for a new

trial based on newly discovered evidence. At trial, a FedEx representative confirmed that it was

its “operating procedure” to extend a company’s shipping discounts to its vendors. R. 75, Pg. ID

397. But at the resentencing hearing, Thomas Murrey (a FedEx Express litigation associate)

-2- Case Nos. 21-5174/5199, United States v. Petlechkov

testified that FedEx’s account managers have discretion to grant shipping discounts to a company’s

vendors. He explained that extending discounts to vendors is just a “standard that’s existed through

the years.” R. 256, Pg. ID 3015. And the company did not have a written policy regarding when

to extend the discounts. Petlechkov moved for a new trial based on Murrey’s testimony, arguing

that it conflicted with the trial testimony. The district court denied the motion.

We review the district court’s denial for an abuse of discretion. United States v. Olender,

338 F.3d 629, 635 (6th Cir. 2003). In doing so, we are mindful that motions for a new trial based

on newly discovered evidence are “disfavored and should be granted with caution.” United States

v. Turns, 198 F.3d 584, 586 (6th Cir. 2000). Indeed, a district court may grant a new trial based

on newly discovered evidence only if the defendant establishes that “(1) the evidence was

discovered after the trial, (2) it could not have been discovered earlier with due diligence, (3) it is

material and not merely cumulative or impeaching, and (4) it would likely produce an acquittal if

the case was retried.” Id. at 586–87; see Olender, 338 F.3d at 635.

To prove Petlechkov committed mail fraud, the government had to show that “he devised

a scheme to defraud, used the mails in furtherance of that scheme, and intended to deprive the

victim of money or property.” Petlechkov, 922 F.3d at 766. The fraudulent scheme “must include

a material misrepresentation.” Id. And that misrepresentation must be one “that could influence

the decision of a ‘person of ordinary prudence and comprehension.’” Id. (alteration adopted)

(quoting United States v. Jamieson, 427 F.3d 394, 415–16 (6th Cir. 2005)).

Petlechkov focuses on the last requirement. According to him, without a written policy

allowing a company’s vendors to receive its discounts, the jury could not have concluded that his

misrepresentation (that he was a General Dynamics vendor) was “calculated to deceive a FedEx

employee of ordinary prudence and comprehension beyond a reasonable doubt.” Appellant’s Br.

-3- Case Nos. 21-5174/5199, United States v. Petlechkov

at 26. In other words, Petlechkov believes the account manager should have been more skeptical

of his deceit. And Petlechkov asserts that his misrepresentation therefore should not have

influenced a “person of ordinary prudence and comprehension.” Petlechkov, 922 F.3d at 766

(cleaned up).

We disagree. To begin, we’ve already held that “Petlechkov’s false statement was capable

of influencing FedEx’s decision.” Id. at 767. And that’s true regardless of whether FedEx has a

written policy governing when a company’s vendors receive its shipping discounts. Written policy

or not, it was “standard” for account managers to extend shipping discounts to vendors. R. 256,

Pg. ID 3015.

In any event, Murrey said nothing that suggests Petlechkov’s false statement could not

have influenced “the decision of a person of ordinary prudence and comprehension.” Petlechkov,

922 F.3d at 766 (cleaned up). In fact, Murrey’s testimony supports the opposite conclusion.

Murrey explained that Petlechkov’s account “looked like a General Dynamics’ account.” R. 256,

Pg. ID 3016. What’s more, Murrey testified that before Petlechkov opened his account with

FedEx, he had used a similar ruse to defraud another shipping company—DHL. But around the

time that Petlechkov opened his FedEx account, DHL ceased domestic operations in the United

States. This led to a rush of DHL customers opening accounts with FedEx. So, according to

Murrey, when Petlechkov asked FedEx to link his account to the General Dynamics account, it

would have “made perfect sense” to FedEx’s account manager. Id. at 3028.

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