United States v. Hunt

688 F. Supp. 265, 1987 U.S. Dist. LEXIS 12950, 1987 WL 42794
CourtDistrict Court, N.D. Texas
DecidedOctober 8, 1987
DocketCR 3-84-238-R
StatusPublished
Cited by3 cases

This text of 688 F. Supp. 265 (United States v. Hunt) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Hunt, 688 F. Supp. 265, 1987 U.S. Dist. LEXIS 12950, 1987 WL 42794 (N.D. Tex. 1987).

Opinion

MEMORANDUM OPINION

BUCHMEYER, District Judge.

This opinion concerns the revocation of probation of a defendant because he failed to act in good faith in attempting to make restitution to the victims of his crime — a credit card scam in which over 7,800 victims were defrauded of at least $264,000. 1

The Law

A defendant’s failure to pay a fine or to make restitution is not grounds for revocation of probation if the default “results from a condition, like poverty, which is attributable to no fault of his own.” United States v. Irvin, 820 F.2d 110, 111 (5th Cir.1987). 2 See also Bearden v. Georgia, 461 U.S. 660, 103 S.Ct. 2064, 76 L.Ed.2d 221 (1983).

However, if the defendant fails “to make a good-faith attempt” to pay the fine or to make restitution, then the conditions of probation have been violated. United States v. Turner, 741 F.2d 696, 698 (5th Cir.1984); United States v. Irvin, 820 F.2d at 111. As stated in United States v. Boswell, 605 F.2d 171, 175 (5th Cir.1979):

“The basic issue is whether at any time between imposition of sentence and revocation of probation the defendant had resources available which could have been used to make the required restitution, in whole or in part. If during the crucial period he had not the resources and no way to acquire them then probation should not have been revoked for a failure to pay.
“On the other hand, if [the defendant] did have the resources available, then the issue is reduced to whether, in fact, he either negligently or deliberately allowed them to be disbursed or dissipated in a manner that resulted in his inability to pay. It must be remembered, however, that revocation may not be inflicted for *266 occurrences, events, or conditions over which [the defendant] had no control.”

These tests—whether framed in terms of “good faith” (Turner), or “negligence” or “deliberate misconduct” (Boswell), or “circumstances beyond the defendant’s control” (Ir vin)—p resent questions of fact and credibility determinations for the trial judge. And, “all that is required for the revocation of probation is enough evidence to satisfy the district judge that the conduct of the [defendant] has not met the conditions of probation.” United States v. Dozier, 707 F.2d 862, 865 (5th Cir.1983); United States v. Irvin, 820 F.2d at 111; United States v. Turner, 741 F.2d at 698.

THE FACTUAL BACKGROUND

(i) the credit card scam

The defendant involved in this probation revocation is Richard L. Hunt.

For over nine months, Hunt and his two co-defendants—Mary Tubbs and Susan Maddox—engaged in a mail fraud scheme involving credit cards. Basically, they ran false advertisements in many publications (such as The National Enquirer); these ads stated that persons could obtain credit cards —regardless of their past credit record —simply by completing an application 3 and returning it with a check for $35.00. But, as described in United States v. Hunt, 794 F.2d 1095, 1097 (5th Cir.1986):

“The complying customer would receive no credit card, however; rather, he would receive only a seven page booklet entitled ‘Ten Easy Steps to Good Credit.’ No advertisement or brochure had mentioned anything about such a booklet, and several customers later testified that the ads led them to expect the delivery of actual credit cards. Those calling the company to complain reached only an answering service. Their complaints, however, eventually reached the United States Postal Service, whose investigation eventually led to the seizure of the companies’ business records and to criminal indictments.”

Before they were stopped, the three defendants had defrauded 10,507 victims of over $358,000. Applications from 2,673 victims were seized, so this money ($86,825.00) was refunded by the Postal Service. However, there remained some 7,800 victims, spread throughout the country, who had been swindled out of over $264,000 by Hunt and his co-defendants. 4

(ii) the sentence of probation

Hunt, Tubbs and Maddox were tried and convicted of multiple counts of mail fraud. United States v. Hunt, 794 F.2d at 1096-97. This Court, in the Presentence Reports, received recommendations to sentence each defendant to a substantial term of imprisonment. Sentencing was set for May 17, 1985.

However, material submitted by the defense attorneys — including a financial statement of the defendant Richard L. Hunt 5 — showed that Hunt had a net worth of $4.7 million. Although the other two defendants had very little money, 6 the evidence at trial demonstrated that (a) the defendant Mary Tubbs had the ability to take care of all administrative and secretarial duties in mailing refunds to the thousands of fraud victims, and (b) the defendant Susan Maddox, with her background in advertising and public relations, had the ability to perform community service designed to prevent others from being defrauded by similar “credit services” schemes. 7

*267 This presented a unique situation. Because of the financial resources of one defendant and the abilities of the other two, it appeared possible to make restitution to the thousands of victims — without any cost to the government. Accordingly, sentencing was deferred to give the three defendants time to submit a detailed proposal both for complete restitution of the $264,-000 to the 7,800 victims and for community service. After their initial submissions— and meetings between the Court and defense counsel — the final proposal of the defendants for “full restitution” was made on August 17, 1985. This proposal (Court Exhibit 1), which was signed by Richard Hunt and his two co-defendants, stated:

“In accordance with your meeting with our attornies (sic), we are re-submitting this proposal in hopes it will be pleasing to the court.
“We agree to make full restitution____ As per the court’s instructions

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Kenneth J. Masat
948 F.2d 923 (Fifth Circuit, 1992)
Ford v. Continental Airlines Corp.
720 F. Supp. 1455 (D. Colorado, 1988)
United States v. Hunt
857 F.2d 1471 (Fifth Circuit, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
688 F. Supp. 265, 1987 U.S. Dist. LEXIS 12950, 1987 WL 42794, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-hunt-txnd-1987.