United States v. Olson

CourtDistrict Court, District of Columbia
DecidedJune 15, 2026
DocketCriminal No. 2025-0069
StatusPublished

This text of United States v. Olson (United States v. Olson) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Olson, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Case No. 25-cr-69-1 (RCL) REDACTED ERLEND OLSON,

Defendant.

MEMORANDUM OPINION & ORDER

Before the Court is Defendant Erlend Olson’s motion to reconsider, ECF No. 112, this

Court’s detention order, ECF No. 30, along with the Government’s opposition, ECF No. 123, and

Olson’s reply, ECF No. 136. The underlying circumstances that motivated this Court’s detention

order have not changed. Olson is alleged to have orchestrated a scheme to defraud about 200

investors and lenders of over $250 million, subjecting him to steep sentencing exposure that

includes a potential life sentence, according to the government’s preliminary estimate. Olson is

further alleged to have concealed over $9 million of these funds and to have lied to government

officials to avoid paying taxes for over a decade. Most importantly, he has significant foreign ties

and has paid to become a dual citizen of a country that offers visa-free travel to many countries

without extradition treaties. And he has attempted to tamper with a witness during the pendency

of this case.

Although serious in light of the projected length of time to trial, the new information

presented in Olson’s motion for reconsideration regarding his health conditions do not overcome

the Court’s original reasons for keeping him detained. The motion for reconsideration and Olson’s

request for an evidentiary hearing will therefore be DENIED.

1 I. BACKGROUND

The Court presumes familiarity with the facts alleged in the Indictment. ECF No. 1. As

relevant here, on March 13, 2025, Olson was charged by indictment in the District of Columbia

with one count of Conspiracy to Commit Wire and Mail Fraud, in violation of 18 U.S.C. § 1349;

five counts of Wire Fraud, in violation of 18 U.S.C. § 1343; one count of Mail Fraud, in violation

of 18 U.S.C. § 1341; and four counts of Tax Evasion, in violation of 26 U.S.C. § 7201. He was

arrested in New Mexico and made his initial appearance at a federal court there on March 17, 2025.

Mem. of Law in Supp. of Emergency Mot. for Revocation at 3, ECF No. 26-1.

The government requested detention based on Olson’s flight risk and obstruction of

justice—specifically citing the hefty sentencing exposure Olson faced if convicted, allegations that

he lied to federal officials to evade taxes, his significant foreign ties, and his attempts to tamper

with witnesses. Gov’t’s Opp’n to Def.’s Emergency Mot. for Revocation at 3–17, ECF No. 28.

After a detention hearing held on March 20, 2025, U.S. Magistrate Judge Jennifer M. Rozzoni of

the District of New Mexico ordered Olson detained pending trial. Order of Detention Pending

Trial at 8, ECF No. 33. On April 4, 2025, Olson filed an emergency motion for revocation of the

magistrate’s detention order, ECF No. 26, the government filed its opposition three days later, ECF

No. 28, and this Court held a bond hearing the day after that. In a Memorandum Opinion issued

on April 9, 2025, this Court denied Olson’s motion to reverse Judge Rozzoni’s detention order,

primarily on the basis that Olson was a flight risk. Mem. Op. at 11, ECF No. 30. Since then,

Olson has spent most of his time at the Northern Neck Regional Jail in Warsaw, Virginia.

About two months ago, Olson filed the present motion asserting “that a number of changes

in circumstances over the last year, in addition to additional facts that have been developed since

that time, warrant reconsideration and revision of” this Court’s order confirming his detention.

2 Def.’s Mot. for Recons., ECF No. 112. In this motion, Olson asks for an evidentiary hearing to

assess these changed circumstances.

II. LEGAL STANDARDS

A. Reconsideration Standard

The Court may reopen a detention hearing “at any time before trial if the judicial officer

finds that information exists that was not known to the movant at the time of the hearing and that

has a material bearing on the issue whether there are conditions of release that will reasonably

assure the appearance of such person as required and the safety of any other person and the

community.” 18 U.S.C. § 3142(f)(2)(B). “[I]n addition to ‘bearing’ on—having a logical relation

to—detention, the sort of new information capable of reopening a detention hearing must also

‘bear’ materially—it must relate in some significant or essential way to the decision whether to

detain.” United States v. Worrell, No. 1:21-cr-292-RCL, 2021 WL 2366934, at *9 (D.D.C. June

9, 2021) (emphasis omitted).

B. Pretrial Detention Standard

The Bail Reform Act of 1984, 18 U.S.C. §§ 3141 et seq., sets forth limited circumstances

in which a defendant may be detained before trial despite the Act’s “presumption in favor of

releasability,” United States v. Leathers, 412 F.2d 169, 171 (D.C. Cir. 1969). The Act requires

that federal courts release a defendant before trial unless a court determines, after a hearing, that

“no condition or combination of conditions will reasonably assure” the defendant’s appearance in

court or the “safety of any other person and the community.” 18 U.S.C. § 3142(e)(1). “In common

parlance, the relevant inquiry is whether the defendant is a ‘flight risk’ or a ‘danger to the

community.’” United States v. Vasquez-Benitez, 919 F.3d 546, 550 (D.C. Cir. 2019).

The government must demonstrate “by a preponderance of the evidence” that pretrial

detention is appropriate based on the defendant’s flight risk. See United States v. Simpkins, 826

3 F.2d 94, 96 (D.C. Cir. 1987) (internal quotation marks omitted). “That preponderance must, of

course, go to the ultimate issue: that no combination of conditions—either those set out in the Bail

Reform Act itself or any others that the magistrate or judge might find useful—can ‘reasonably’

assure that the defendant will appear for trial.” United States v. Xulam, 84 F.3d 441, 442 (D.C.

Cir. 1996) (quoting 18 U.S.C. § 3142(c)).

III. DISCUSSION

To determine whether any conditions of release will reasonably assure Olson’s appearance,

the Court must “take into account the available information concerning” the following four factors

set out in 18 U.S.C. § 3142(g):

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