United States v. Robert Richardson

CourtCourt of Appeals for the Sixth Circuit
DecidedFebruary 17, 2021
Docket20-5282
StatusUnpublished

This text of United States v. Robert Richardson (United States v. Robert Richardson) 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.

Bluebook
United States v. Robert Richardson, (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0092n.06

Case Nos. 20-5281/5282

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Feb 17, 2021 ) DEBORAH S. HUNT, Clerk UNITED STATES OF AMERICA, ) ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE EASTERN DISTRICT OF ) TENNESSEE ROBERT S. RICHARDSON, ) ) Defendant-Appellant. )

BEFORE: MOORE, ROGERS, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. Robert S. Richardson was caught submitting a

fraudulent passport application. After Richardson pleaded guilty to various federal crimes related

to the incident, further revelations about his near quarter century of deceiving others as to his

identity came to light. This long history of deceit coupled with his lack of candor to the district

court and its officers following his arrest prompted the district court to impose a sentence of 48

months of imprisonment, which exceeded the guidelines range by 12 months. Before this Court,

Richardson challenges the sentence’s reasonableness. Finding no abuse of discretion, we affirm.

BACKGROUND

While living in South Carolina, Robert Richardson visited a Tennessee post office,

ostensibly to replace his missing passport. The passport application he submitted listed the Case Nos. 20-5281/5282, United States v. Richardson

applicant’s name as Robert Ayer Richardson and his date of birth as October 3, 1958.

The application also listed a Social Security number and a place of birth (Columbia, South

Carolina). To support his application, Richardson showed the postal clerk a driver’s license and

two credit cards, each of which identified the applicant as Robert Ayer Richardson.

Upon reviewing the application, federal authorities became suspicious. Following an

investigation, the authorities learned that a passport renewal application for Robert Ayer

Richardson submitted just two years earlier had been rejected. Authorities also discovered that

Robert Ayer Richardson was born in Newberry (not Columbia), South Carolina. And, authorities

learned, Robert Ayer Richardson was dead. Subsequent investigations revealed that the renewal

application was submitted by Robert Stone Richardson, born February 3, 1950. That Robert

Richardson, while alive and seemingly well, was later charged with attempting to renew a passport

he had fraudulently obtained decades earlier in the name of Robert Ayer Richardson. Richardson

eventually pleaded guilty to passport, Social Security, and identity fraud charges.

When it came to Richardson’s fondness for deception, the proverb “old habits die hard”

could not be more fitting. For even in the face of federal fraud charges, Richardson stayed true to

form, providing what likely amounted to false information to two different probation departments

during his presentence interview. For example, three of the companies Richardson disclosed to

the probation office as former employers either denied having ever employed Richardson or lacked

any record of doing so. And despite Richardson’s telling probation officers that he lived and

worked in China during the mid-1990s, U.S. Customs and Border Protection had no record of

Richardson ever traveling to China during that period. On top of that, Richardson refused to use

his full name in his plea agreement, signing as “R. Richardson,” and thereby prompting prosecutors

to make him testify under penalty of perjury to establish his true identity.

2 Case Nos. 20-5281/5282, United States v. Richardson

All of this set the stage for Richardson’s sentencing. The district court calculated the

Sentencing Guidelines range for Richardson’s offenses to be 30 to 36 months. Richardson sought

a sentence of 30 months or less on the grounds that he had initially assumed the identity of Robert

Ayer Richardson, who was about eight years younger, to combat years of frustration with ageism

in the job market. To Richardson, his crime was solely the result of trying to “keep a roof over his

family’s head, put adequate food on the table, and provide for” his loved ones. Richardson also

noted his accomplishments as an engineer and as a competitive bodybuilder, which, according to

Richardson, culminated in his placing in the Mr. America contest in 1988.

The government, by contrast, sought an upward variance of 60 months based on the scope

and duration of Richardson’s misconduct as well as the lack of respect he had shown for the law

following his arrest. New evidence discovered leading up to Richardson’s sentencing only

strengthened the government’s hand. Richardson’s estranged fiancée disclosed multiple

fraudulent forms of identification dating back to the 1980s formerly possessed by Richardson,

including IDs using a variation on the name Jeffrey Butler. Federal investigators, moreover, could

not find Richardson’s name on any records of the Mr. America finalists in the late 1980s.

Richardson resisted the government’s narrative, characterizing the government’s investigations

into his history and employment claims as inconclusive. His main contention, however, was that

an upward variance was unjustified given the lack of any concrete harm to an identifiable victim.

The district court varied the sentence upward, sentencing Richardson to 48 months of

imprisonment. Richardson’s timely appeal followed.

ANALYSIS

1. Richardson makes two arguments as to why his sentence was unreasonable. He first

contends that the sentence was based on an impermissible factor—namely, “unfounded

3 Case Nos. 20-5281/5282, United States v. Richardson

speculation” that he had engaged in additional fraudulent activity. While Richardson frames his

argument as a challenge to the substantive reasonableness of the sentence, we view the

“consideration of an impermissible factor . . . [as] a procedural, not substantive, error.” United

States v. Cabrera, 811 F.3d 801, 809 (6th Cir. 2016). At bottom, an argument that a sentence

resulted from unreasonable speculation is “simply another way of saying that the district court

selected a sentence based on clearly erroneous facts.” United States v. Parrish, 915 F.3d 1043,

1047 (6th Cir. 2019) (cleaned up). Before we will reverse a sentence on this ground, we must be

left with a “definite and firm conviction” that the district court made a mistake. United States v.

Donadeo, 910 F.3d 886, 893 (6th Cir. 2018). We apply the abuse-of-discretion standard in

evaluating the reasonableness of a sentence. Id.

The district court made no mistake here. Its conclusion that Richardson engaged in

additional fraudulent conduct was based not on speculation, but rather on unrefuted evidence

showing that Richardson possessed almost a dozen fraudulent forms of identification. Several of

Richardson’s fake IDs utilized a different name—Jeffrey Butler—and at least one dated back to

the early 1980s. All of this undermined Richardson’s argument that his fraud was limited in its

purpose and scope to boosting his job prospects as he aged. From this evidence, the district court

could reasonably infer that Richardson had engaged in extended fraud not reflected in his criminal

history. See United States v. Howder, 748 F. App’x 637, 644 (6th Cir. 2018) (observing that

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

Related

United States v. Davila-Gonzalez
595 F.3d 42 (First Circuit, 2010)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Paul Delgado
427 F. App'x 498 (Sixth Circuit, 2011)
United States v. Aleo
681 F.3d 290 (Sixth Circuit, 2012)
United States v. Stephen Graham-Wright
715 F.3d 598 (Sixth Circuit, 2013)
United States v. Brock
501 F.3d 762 (Sixth Circuit, 2007)
United States v. Anthony Van
541 F. App'x 592 (Sixth Circuit, 2013)
United States v. Donovan Wayne Tucker
315 F. App'x 220 (Eleventh Circuit, 2009)
Ocasio v. United States
578 U.S. 282 (Supreme Court, 2016)
United States v. Randy Poulson
871 F.3d 261 (Third Circuit, 2017)
United States v. David Donadeo
910 F.3d 886 (Sixth Circuit, 2018)
United States v. Richard Parrish
915 F.3d 1043 (Sixth Circuit, 2019)
United States v. John Rankin
929 F.3d 399 (Sixth Circuit, 2019)
United States v. Rene Boucher
937 F.3d 702 (Sixth Circuit, 2019)
United States v. Ediberto Aguilar-Calvo
945 F.3d 464 (Sixth Circuit, 2019)
United States v. Cabrera
811 F.3d 801 (Sixth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Robert Richardson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-robert-richardson-ca6-2021.