United States v. Martins Inalegwu

CourtCourt of Appeals for the Third Circuit
DecidedJuly 16, 2025
Docket24-2594
StatusUnpublished

This text of United States v. Martins Inalegwu (United States v. Martins Inalegwu) 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. Martins Inalegwu, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 24-2594 ____________

UNITED STATES OF AMERICA

v.

MARTINS INALEGWU, a/k/a Martins Friday Inalegwu, Appellant ____________

On Appeal from the United States District Court for the District of New Jersey (D.C. Criminal No. 1:23-cr-00282-001) District Judge: Honorable Christine P. O’Hearn ____________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) June 5, 2025

Before: HARDIMAN, BIBAS, and FISHER, Circuit Judges.

(Filed: July 16, 2025) ____________

OPINION* ____________

FISHER, Circuit Judge.

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Martins Inalegwu participated in a widespread and complex financial fraud

scheme. Once apprehended, he pled guilty to committing, and conspiring to commit,

illegal money transmission1 and income tax evasion.2 Inalegwu and the Government

agreed that his offense level was 28, with Inalegwu potentially being eligible for multiple

reductions, including a two-level reduction as a zero-point offender.3 However, the

District Court declined to impose the reduction given the severity of the crime and

sentenced Inalegwu to 80 months’ imprisonment. On appeal, Inalegwu argues that we

should vacate his sentence because the District Court erred in its Guidelines calculation

and violated his right to allocution by cross-examining him during his sentencing

allocution.4 We, however, perceive no such errors and will affirm the sentence of the

District Court.

First, Inalegwu argues that the District Court miscalculated his Guidelines range

by denying the zero-point offender reduction. We review the District Court’s

interpretation of the Guidelines de novo, we review its factual findings for clear error,

“and we ‘give due deference to the district court’s application of the [G]uidelines to the

1 18 U.S.C. §§ 1960, 2. 2 26 U.S.C. § 7201; 18 U.S.C. § 2. 3 U.S.S.G. § 4C1.1. 4 The District Court had subject matter jurisdiction under 18 U.S.C. § 3231 (federal crimes). We have appellate jurisdiction under both 18 U.S.C. § 3742(a) (review of a sentence) and 28 U.S.C. § 1291 (final decisions of district courts).

2 facts.’”5 To be eligible for the zero-point offender reduction, Inalegwu must not have

“personally cause[d] substantial financial hardship.”6 While the parties invite us to opine

on the contours of personally causing financial hardship, we do not need to do so here:

“[e]ven if we determine that the District Court committed procedural error,” such as

miscalculating the Guidelines range as Inalegwu argues, “we may still uphold its

sentence if the error was harmless.”7

Miscalculating the Guidelines is a non-constitutional error and “is harmless when

‘it is highly probable that the error did not prejudice’ the defendant.”8 If the record

establishes “that there is a high probability ‘that the sentencing judge would have

imposed the same sentence under a correct Guidelines range,’” it is highly probable that

the defendant was not prejudiced by the calculation error.9 When discerning whether this

high probability exists, we may consider whether the court made a clear statement of its

intent to impose the same sentence even if the range were calculated differently, whether

the sentence departed from the advisory range, and whether the court demonstrated

awareness of the relevant facts and circumstances.10

5 United States v. Zabielski, 711 F.3d 381, 386 (3d Cir. 2013) (quoting United States v. Thomas, 327 F.3d 253, 255 (3d Cir. 2003)). 6 U.S.S.G. § 4C1.1(a)(6). 7 Zabielski, 711 F.3d at 386. 8 United States v. Langford, 516 F.3d 205, 215 (3d Cir. 2008) (citation omitted). 9 Zabielski, 711 F.3d at 387 (quoting Langford, 516 F.3d at 216). 10 See id. at 387–90 (noting it is sometimes discernible from the record that the choice between two possible Guidelines ranges “did not affect the actual sentence”).

3 Here, the District Court heard argument on the zero-point offender adjustment and

reviewed the parties’ offered authority. It then made a “clear statement” that it “would

have imposed the same sentence regardless of” which range applied.11 When handing

down Inalegwu’s 80-month sentence, the sentencing court “want[ed] to specifically note

[it] would have imposed this sentence, quite frankly, even if [it] had sustained the

defendant’s objections on the zero-point offender [reduction].”12

Still, Inalegwu argues that the District Court’s failure to explain the alternative

sentence establishes that he was harmed by the alleged miscalculation. While it is true

that clear statements alone are probative but not dispositive of harmless error, the District

Court “explain[ed] its reasons” for sentencing Inalegwu to 80 months’ imprisonment

“under either Guidelines range.”13 It stated that “the seriousness of the offense . . .

warrants a severe and substantial penalty” 14 given its duration and the complexity and

sophistication of Inalegwu’s role in the scheme.15

Our conclusion that any alleged error was harmless is further supported by the fact

that the District Court imposed a sentence well above the Guidelines range (57 to 71

months) and the range that would have applied with the adjustment (46 to 57 months).

When the record shows a clear variance from the disputed Guidelines range and suggests

11 See id. at 387. 12 App. 152–53. 13 See Zabielski, 711 F.3d at 389. 14 App. 153. 15 App. 149.

4 that the sentence was not influenced by that range, “we can be certain that” any alleged

error “had no effect on the sentence imposed.”16

Finally, the District Court’s thorough analysis of the circumstances surrounding

Inalegwu’s offenses further supports our conclusion “that it would have imposed the

same sentence” regardless of any error because sentencing enhancements and reductions

are meant to “train the district court’s attention on the details of the crime.”17 Here, the

District Court extensively questioned Inalegwu, then deliberately imposed the 80-month

sentence to reflect the complexity of the offense, including its enduring harm to the

victims. The District Court also emphasized the need for “adequate general deterrence for

this type of conduct.”18 Because the foregoing convinces us that any alleged procedural

error in calculating Inalegwu’s applicable Guidelines range was harmless, we decline to

vacate his sentence.

Second, Inalegwu argues that the sentencing judge impermissibly cross-examined

him during his allocution. Because he did not object to this questioning at the time of his

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United States v. Mark Zabielski
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United States v. Lawrence Ward
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