United States v. Kimberly Sponaugle

CourtCourt of Appeals for the Third Circuit
DecidedSeptember 11, 2024
Docket22-2851
StatusUnpublished

This text of United States v. Kimberly Sponaugle (United States v. Kimberly Sponaugle) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Kimberly Sponaugle, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

________________

No. 22-2851 ________________

UNITED STATES OF AMERICA

v.

KIMBERLY SPONAUGLE, Appellant _____________

On Appeal from the United States District Court for the District of Delaware (D.C. Criminal No. 1-19-cr-00103-001) District Judge: Honorable Leonard P. Stark ________________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) on April 9, 2024

Before: CHAGARES, Chief Judge, PORTER, and SCIRICA, Circuit Judges.

(Filed: September 11, 2024)

OPINION * ________________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. SCIRICA, Circuit Judge

Kimberly Sponaugle appeals her conviction for wire fraud. She argues that the

District Court erred in granting the Government’s motion in limine to (1) admit lay

opinion testimony of accountants with personal knowledge of her scheme to defraud her

employer; (2) introduce her tax returns as intrinsic evidence of fraud and evidence of her

intent and knowledge; and (3) preclude her from introducing a government witness’s

efforts to correct her testimony in an unrelated proceeding. We disagree and will affirm

the District Court’s judgment of conviction and sentence.

I.

From 2005 to 2018, Kimberly Sponaugle worked as an office manager for All

About Women (“AAW”), a small, privately-owned healthcare practice in Delaware. Her

responsibilities included reviewing monthly checking and credit card statements, entering

financial information into the company’s QuickBooks ledger, and tracking credit card

charges and reimbursements. AAW retained the accounting firm Stephano Slack to

reconcile their accounts, but the firm did not have access to or review AAW’s credit card

statements. Sponaugle nevertheless told AAW’s head partner, Dr. Diane McCracken,

that Stephano Slack performed monthly audits of AAW’s accounts, which would have

involved a review of credit card statements.

AAW gave Sponaugle a corporate credit card to use for business-related expenses.

Sponaugle knew that if she used her AAW credit card to make a personal purchase, she

would have to reimburse the company.

Beginning in 2012 and continuing until her termination in 2018, Sponaugle made

2 numerous unauthorized, personal purchases with her AAW credit card and paid her

AAW credit card bills with electronic transfers from the company’s checking account.

She concealed her purchases by mislabeling them in AAW’s QuickBooks ledger.

In March 2018, McCracken discovered Sponaugle’s unauthorized personal

transactions, which prompted her to ask Certified Public Accountant (“CPA”) Ralph

Cetrulo and accountant Kathy Storm at Stephano Slack to investigate Sponaugle’s

spending. AAW terminated Sponaugle and contacted law enforcement. An FBI

investigation determined Sponaugle made over 3,000 unauthorized transactions totaling

over $250,000.

Sponaugle was charged with one count of wire fraud, in violation of 18 U.S.C.

§ 1343. In its pretrial memorandum and omnibus motion in limine, the Government

sought several evidentiary rulings, which the District Court addressed during a pretrial

conference.

First, the Government sought to admit lay opinion testimony from Cetrulo, Storm,

and FBI forensic accountant Michelle Hoffman. The Government explained that Cetrulo

would discuss preparing Sponaugle’s tax returns, describe what information he usually

sought from clients when preparing taxes, and provide lay opinion testimony respecting a

taxpayer’s obligation to declare non-monetary income on her taxes. Next, the

Government explained that Storm would testify about how QuickBooks software is used

for bookkeeping, as well as the difference between reconciliations, which Storm

performed for AAW, and more thorough accounting practices like audits. Finally, the

Government explained that Hoffman would testify about her participation in the FBI’s

3 investigation into Sponaugle’s spending. Hoffman would also explain whether AAW’s

ledgers were consistent with the proper use of QuickBooks based on her personal

knowledge of the software as a forensic accountant. The Government argued that all

three accountants could give lay opinion testimony because of their personal knowledge,

either as AAW’s outside accountants or as an FBI investigator.

Sponaugle objected to the Government’s request to admit the accountants’

testimony as lay opinion testimony, explaining that any testimony they could give about

accounting, bookkeeping, or the operation of QuickBooks software would rely on

specialized knowledge. Sponaugle also objected to the Government’s purported failure

to provide written summaries of the basis for their testimony as required for the

admission of expert testimony under Federal Rule of Criminal Procedure 16(a)(1)(G).

The District Court granted the Government’s motion to admit the accountants’ lay

opinion testimony, finding that the testimony was based on personal knowledge. The

District Court also concluded that because the accountants were giving lay witness

testimony, the Government did not need to provide Rule 16(a)(1)(G) disclosures.

Second, the Government sought to admit Sponaugle’s tax returns. The

Government argued that Sponaugle’s failure to report her non-monetary income from

AAW was intrinsic evidence that helped to directly prove the wire fraud charge by

showing her intent to defraud and knowledge of the fraud. The Government also argued

that these omissions from Sponaugle’s tax returns were evidence of contemporaneous,

uncharged acts that facilitated the charged offense. In the alternative, the Government

argued that her tax returns were admissible, relevant evidence of Sponaugle’s intent and

4 knowledge under Federal Rule of Evidence 404(b).

Sponaugle objected to the Government’s use of the tax returns as evidence that she

committed wire fraud, arguing that their admission for that purpose would require a “mini

trial” on her knowledge of taxable income and that their probative value was substantially

outweighed by the potential of unfair prejudice.

The District Court granted the Government’s motion, finding that the tax returns

were intrinsic evidence of wire fraud, as well as valid, non-propensity evidence of

Sponaugle’s intent and knowledge of the crime under Rule 404(b). The District Court

found that any potential prejudice was outweighed by the probative value of the evidence,

especially because the District Court would prohibit the Government from suggesting or

arguing that Sponaugle committed tax fraud.

Third, the Government sought to preclude Sponaugle from introducing evidence

of McCracken’s attempt to submit a deposition errata sheet in an unrelated medical

malpractice action in Delaware Superior Court. There, the Superior Court granted the

plaintiff’s motion to strike McCracken’s errata sheet, noting that her proposed changes

were significant enough to frustrate the purpose of the deposition. The Government

argued that extrinsic evidence of the deposition, the errata sheet, and the Superior Court’s

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