United States v. Kenneth Patterson

CourtCourt of Appeals for the Ninth Circuit
DecidedApril 25, 2023
Docket22-10113
StatusUnpublished

This text of United States v. Kenneth Patterson (United States v. Kenneth Patterson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth 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. Kenneth Patterson, (9th Cir. 2023).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 25 2023 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 22-10113

Plaintiff-Appellee, D.C. No. 1:19-cr-00230-DAD-BAM-1 v.

KENNETH SHANE PATTERSON, MEMORANDUM*

Defendant-Appellant.

Appeal from the United States District Court for the Eastern District of California Dale A. Drozd, District Judge, Presiding

Argued and Submitted April 10, 2023 San Francisco, California

Before: PAEZ, CLIFTON, and H.A. THOMAS, Circuit Judges.

Kenneth Patterson pleaded guilty to federal charges of wire fraud, bank

fraud, and tax evasion. The wire fraud charges stemmed from a two-and-a-half-

year scheme during which he extracted multiple payments from his victim on the

false premise that he would acquire a skilled nursing facility for her to purchase.

Based on the nature of this scheme and false statements that Patterson made during

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. his bond revocation proceedings, the district court applied sentencing

enhancements for abuse of a position of trust, use of sophisticated means, and

obstruction of justice. The district court also ordered Patterson to pay restitution to

the victims of his offenses and to the State of California Franchise Tax Board.

On appeal, Patterson challenges the district court’s application of the

sentencing enhancements and its authority to issue the restitution order. We have

jurisdiction under 28 U.S.C. § 1291, and we vacate and remand for resentencing.

We review de novo a district court’s interpretation of the United States

Sentencing Guidelines (U.S.S.G. or Guidelines), review for clear error its factual

findings, and review for abuse of discretion its application of the Guidelines to the

facts of the case. United States v. Gomez-Leon, 545 F.3d 777, 782 (9th Cir. 2008).

1. Abuse of position of trust enhancement. We hold that the district court

erred in applying the position of trust enhancement as provided in U.S.S.G.

§ 3B1.3. Patterson did not occupy a position of trust relative to his victim in their

deal to acquire the nursing facility.

A position of trust is “characterized by professional or managerial discretion

(i.e., substantial discretionary judgment that is ordinarily given considerable

deference).” Id. § 3B1.3 app. n.1. The fact that Patterson’s victim trusted him,

even if that trust was based on past representations about his business skills or

experience, is not sufficient. Rather, “the presence or lack of professional or

2 managerial discretion represents the decisive factor in deciding whether a

defendant occupied a position of trust.” United States v. Laurienti, 731 F.3d 967,

973 (9th Cir. 2013) (internal quotation marks omitted); see United States v.

Thomsen, 830 F.3d 1049, 1073–74 (9th Cir. 2016). Patterson did not wield such

discretion in his deal with the victim to acquire the nursing facility. He had no

latitude to use the money that she sent him to obtain the nursing facility for any

other purpose, nor did he provide investment advice or owe her a fiduciary duty.

The relationship between Patterson and his victim during the deal underlying the

offense thus falls short of what our cases require for a position of trust, and the

enhancement does not apply.

2. Sophisticated means enhancement. The district court abused its discretion

in applying the sophisticated means enhancement under U.S.S.G.

§ 2B1.1(b)(10)(C). Our past decisions do not support the premise that fraudulent

conduct that took place over a long period of time is sufficient to justify the

enhancement. Repeated actions alone do not constitute sophisticated means.

Rather, the defendant’s steps to commit or conceal the offense should also be

“coordinated” and “comparable in ‘sophistication’ to schemes held to warrant the

enhancement.” Thomsen, 830 F.3d at 1073 (quoting United States v. Augare, 800

F.3d 1173, 1175–76 (9th Cir. 2015)). Without exception, our cases upholding this

enhancement have involved more complicated conduct than Patterson’s offense.

3 See, e.g., Augare, 800 F.3d at 1175; Thomsen, 830 F.3d at 1054; United States v.

Horob, 735 F.3d 866, 872 (9th Cir. 2013) (per curiam); United States v. Tanke, 743

F.3d 1296, 1307 (9th Cir. 2014).

Patterson dealt directly with his victim throughout the scheme, and she

always knew to whom she was making payments. Except for one payment to

Patterson’s business associate, she and Patterson were the only two people ever

involved in the transactions. Patterson did not fabricate documents, coordinate

with other parties, transfer funds between different accounts, or otherwise use

comparable methods. His ruse consisted of a protracted lie about his progress

toward acquiring a nursing facility that induced direct payments from a single

victim. The straightforward nature of this offense distinguishes it from cases

where we have affirmed the enhancement.

3. Obstruction of justice enhancement. The district court correctly applied

the obstruction of justice enhancement under U.S.S.G. § 3C1.1 based on Patterson’s

false statements regarding violations of his conditions of pretrial release.

“[A] defendant who willfully provides materially false testimony to a judge

during a bond revocation hearing may be subject to a sentence enhancement under

section 3C1.1.” United States v. Taylor, 749 F.3d 842, 847 (9th Cir. 2014). We

have also held that “providing materially false information to a pretrial services

officer, whose job it is to conduct investigations for the court, constitutes

4 obstruction of justice for purposes of section 3C1.1, without a specific showing

that the falsehood actually obstructed justice.” United States v. Magana-Guerrero,

80 F.3d 398, 401 (9th Cir. 1996); see also United States v. Manning, 704 F.3d 584,

586 (9th Cir. 2012) (per curiam) (“[I]t suffices that [the defendant] fooled a Pretrial

Services officer, or tried to. He need not actually have obstructed the

investigation; it suffices that he ‘attempted’ to do so.”). A “material” statement is

one that, “if believed, would tend to influence or affect the issue under

determination.” U.S.S.G. § 3C1.1 app. n.6.

Patterson’s false statements to his pretrial services officer and to the district

court, if believed, would have affected his bond revocation proceedings. The

obstruction of justice enhancement was warranted under these circumstances.

4. Restitution order. The district court plainly erred in ordering restitution

for Patterson’s tax evasion conviction under Internal Revenue Code (I.R.C.)

§ 7201 in two respects. 1

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

Related

United States v. Batson
608 F.3d 630 (Ninth Circuit, 2010)
United States v. Dale Manning
704 F.3d 584 (Ninth Circuit, 2012)
United States v. Bryan Laurienti
731 F.3d 967 (Ninth Circuit, 2013)
United States v. Gomez-Leon
545 F.3d 777 (Ninth Circuit, 2008)
United States v. Todd Horob
735 F.3d 866 (Ninth Circuit, 2013)
United States v. Thomas Tanke
743 F.3d 1296 (Ninth Circuit, 2014)
United States v. Terazze Taylor
749 F.3d 842 (Ninth Circuit, 2014)
United States v. Delyle Augare
800 F.3d 1173 (Ninth Circuit, 2015)
United States v. Neil A. Thomsen
830 F.3d 1049 (Ninth Circuit, 2016)
United States v. Yijun Zhou
838 F.3d 1007 (Ninth Circuit, 2016)
United States v. Magana-Guerrero
80 F.3d 398 (Ninth Circuit, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Kenneth Patterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kenneth-patterson-ca9-2023.