United States v. Jeremy Jones

CourtCourt of Appeals for the Sixth Circuit
DecidedJune 9, 2020
Docket19-5069
StatusUnpublished

This text of United States v. Jeremy Jones (United States v. Jeremy Jones) 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.

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United States v. Jeremy Jones, (6th Cir. 2020).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 20a0333n.06

Case No. 19-5069

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jun 09, 2020 DEBORAH S. HUNT, Clerk UNITED STATES OF AMERICA, ) ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF JEREMY JONES, ) TENNESSEE ) Defendant-Appellant. )

BEFORE: BOGGS, SUTTON, and WHITE, Circuit Judges.

SUTTON, Circuit Judge. After Jeremy Jones stole the identities of over a hundred people,

a jury found him guilty of aggravated identity theft and several related crimes. On appeal, Jones

targets a double-jeopardy violation and challenges his sentence. We vacate one of the convictions

but affirm in all other respects.

Jones convinced a few friends to give him their personal information, promising to help

them improve their credit or to use the information for joint business ventures. He instead used it

to take out car loans for himself. When that worked, Jones upped the game. He enlisted the help

of his ex-girlfriend, Carla Daughtery, who worked at a neurology clinic in Memphis. For over a

year, Daughtery periodically gave Jones the personal information of doctors, nurses, and patients

at the clinic. He used it for more of the same: setting up loans, credit cards, and bank accounts in Case No. 19-5069, United States v. Jones

the victims’ names. Jones promised Daughtery “big money” for her help. R. 172 at 7. But he

kept the money for himself.

The government learned about Jones’s scheme when some financial institutions reported

the suspicious transactions. After linking several of them to Jones’s IP address, the government

executed a search warrant at his home. The search revealed extensive evidence tying Jones to

identity theft, including a computer with the personal information of over 100 individuals, along

with credit cards and loan applications in their names. Because most of the victims were patients

of the same neurology clinic, the government managed to uncover Daughtery’s role in the scheme

and convinced her to testify against Jones. A grand jury indicted him on four counts: conspiracy

to commit identity theft and mail fraud, identity theft, mail fraud, and aggravated identity theft.

See 18 U.S.C. §§ 371, 1028(a)(7), 1028A, 1341.

Jones contacted some of the friends he had first swindled and encouraged them to change

their stories. That led to two charges of obstruction of justice. A jury convicted Jones on all

counts.

At sentencing, the court determined that Jones was responsible for losses of $1.98 million,

which led to a 16-level enhancement. See U.S.S.G. § 2B1.1(b)(1)(I). With that enhancement and

a few others factored in, Jones’s guidelines range stood at 94 to 111 months. See 18 U.S.C.

§ 1028A(a)(1), (b)(2); U.S.S.G. § 2B1.6. The court imposed a within-guidelines sentence of 102

months. Jones appeals on three grounds.

Double Jeopardy. The Double Jeopardy Clause says that no one should “be twice put in

jeopardy” for “the same offense.” U.S. Const. amend. V. A defendant may be convicted of

multiple crimes arising from the same course of conduct so long as each crime “requires proof of

2 Case No. 19-5069, United States v. Jones

a fact which the other does not.” Blockburger v. United States, 284 U.S. 299, 304 (1932); see

United States v. Kurlemann, 736 F.3d 439, 452 (6th Cir. 2013).

As the government concedes, Jones’s convictions for identity theft and aggravated identity

theft fail the Blockburger test. The first three elements of each crime use the same language:

(1) “knowingly transfers, possesses, or uses,” (2) “without lawful authority,” (3) “a means of

identification of another person.” Compare 18 U.S.C. § 1028(a)(7), with 18 U.S.C. § 1028A(a)(1).

That leaves the fourth element. Identity theft requires that the first three elements occur “in

connection with[] any unlawful activity that constitutes a violation of Federal law” or a state

felony, id. § 1028(a)(7), while aggravated identity theft lists specific predicate federal crimes that

trigger this section. Id. § 1028A(a)(1), (c). Because any of the federal law predicates is “a

violation of Federal law,” anyone who commits aggravated identity theft necessarily commits

identity theft. The only two circuits to consider the question have taken this straightforward path.

See United States v. Bonilla, 579 F.3d 1233, 1242–44 (11th Cir. 2009); United States v. Allen, 781

F. App’x 513, 515–16 (7th Cir. 2019). The government concedes as much.

The question is what to do next. Jones does not argue he is entitled to a full-blown re-

sentencing hearing. The debate is whether we should vacate the lesser included identity-theft

conviction (as the government asks) or give the district court discretion to decide which of the two

offenses to vacate (as Jones asks).

There is no room for discretion. It would be an unjust windfall “to give the defendant a

shorter sentence than he would have received had the government not also charged him with the

less serious offense.” United States v. Peel, 595 F.3d 763, 768 (7th Cir. 2010). That is even clearer

when the less serious offense is also the lesser included one: “[I]magine convicting a person of

attempted murder and of murder and punishing him only for the attempt.” Id. Unpublished

3 Case No. 19-5069, United States v. Jones

decisions in our circuit have followed this approach. United States v. Gerick, 568 F. App’x 405,

408 (6th Cir. 2014); United States v. Hutchinson, 448 F. App’x 599, 603–04 (6th Cir. 2012). And

the two out-of-circuit appellate decisions dealing with the same double jeopardy problem as in the

case before us—overlapping convictions for identity theft and aggravated identity theft—vacated

the identity-theft conviction. See Bonilla, 579 F.3d at 1243–44, 1246; Allen, 781 F. App’x at 516.

Jones does not attempt to distinguish these cases. He instead cites others where the court

remanded for the district court to select which conviction to vacate. See, e.g., Rutledge v. United

States, 517 U.S. 292, 307 (1996); Ball v. United States, 470 U.S. 856, 864 (1985); United States

v. Ehle, 640 F.3d 689, 699 (6th Cir. 2011). But these cases did not consider the question at hand.

United States v. Chambers, it is true, did face the issue and remanded to the district court.

944 F.2d 1253, 1269 (6th Cir. 1991). But in that case, due to a quirk in the (then-mandatory)

sentencing guidelines, the lesser-included offense carried the greater sentence. Id. at 1268–69.

Given that anomaly, the court took what it recognized as an anomalous approach. Id. at 1269.

Consecutive sentences.

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Related

United States v. Bonilla
579 F.3d 1233 (Eleventh Circuit, 2009)
Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Ball v. United States
470 U.S. 856 (Supreme Court, 1985)
Rutledge v. United States
517 U.S. 292 (Supreme Court, 1996)
United States v. McCarty
628 F.3d 284 (Sixth Circuit, 2010)
United States v. Ehle
640 F.3d 689 (Sixth Circuit, 2011)
United States v. Kenneth Hutchinson
448 F. App'x 599 (Sixth Circuit, 2012)
United States v. Anastasios S. Katzopoulos
437 F.3d 569 (Sixth Circuit, 2006)
United States v. Kevin Jemel Mickens
453 F.3d 668 (Sixth Circuit, 2006)
United States v. Eric Duke
736 F.3d 439 (Sixth Circuit, 2013)
United States v. Peel
595 F.3d 763 (Seventh Circuit, 2010)
United States v. White
492 F.3d 380 (Sixth Circuit, 2007)
United States v. James Hardison
365 F. App'x 661 (Sixth Circuit, 2010)
United States v. Thomas Gerick
568 F. App'x 405 (Sixth Circuit, 2014)
United States v. John Roberts
919 F.3d 980 (Sixth Circuit, 2019)
United States v. Adam Vance
956 F.3d 846 (Sixth Circuit, 2020)

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