United States v. Thomas Charles Bridges

Court of Appeals for the Eleventh Circuit·Decided August 22, 2025·No. 24-11909·Unpublished

Opinion

[DO NOT PUBLISH]

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-11909

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus THOMAS CHARLES BRIDGES,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Alabama D.C. Docket No. 1:23-cr-00082-TFM-B-1

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Before JORDAN, LUCK, and TJOFLAT, Circuit Judges. PER CURIAM:

Thomas Bridges appeals his 96-month sentence for conspiracy to commit bank fraud. He argues (1) that the District Court clearly erred in finding that he continued to engage in bank fraud while on pretrial release, (2) that the Government breached his plea agreement by informing the District Court of his continued criminal conduct, and (3) that the District Court clearly erred when it applied a two-level sentencing enhancement for having a leadership role in the conspiracy. We affirm.

I.

Bridges was indicted for conspiracy to commit bank fraud, substantive bank fraud, and possession of counterfeited or forged securities. He was arrested, arraigned, and released on conditions requiring him to refrain from committing “any offense in violation of federal, state or local law while on release.” Bridges ultimately pleaded guilty to the conspiracy charge under a written plea agreement . Under that agreement, the Government would dismiss all other charges and recommend a sentence at the low end of the applicable Guidelines range. The agreement also stated that “because Bridges recruited others to participate in the scheme, a two-level role enhancement should apply pursuant to U.S.S.G. § 3B1.1(c)” and that both parties were “free to allocute fully at the time of sentencing .” Further, the corresponding factual resume stated that Bridges engaged in various acts in furtherance of the scheme,

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including depositing checks, “acquir[ing] a printer and magnetic ink,” and “exchang[ing] numerous text messages” with co-conspirators .

While on pretrial release, Bridges allegedly continued his fraudulent conduct. According to the Government’s sentencing memorandum and supporting exhibits, a local school placed fourteen checks in the U.S. mail, which were subsequently stolen, altered and forged, and deposited into the bank accounts of various individuals who were not authorized to deposit the checks and who were not associated with the school. A bank then submitted one of the checks for inspection, and latent fingerprint analysis identified Bridges’s fingerprint on the check. An inspector also found messages sent from an iCloud account bearing Bridges’s name, sent while Bridges was on pretrial release, that discussed fraudulent check activities.

Bridges’s presentence investigation report calculated a total offense level of 24 based on a base offense level of 25, a two-level enhancement for being a leader in the criminal activity, and a reduction of three levels because Bridges accepted responsibility. The report also calculated a criminal history category of I, a Guidelines imprisonment range of 51–63 months, and a Guidelines range of supervised release of 2–5 years.

At the sentencing hearing, Bridges objected to the two-level role enhancement to his base offense level because he merely recruited people into the scheme, claiming that recruitment is different from leadership. The Government maintained not only that

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Bridges agreed to the two-level role enhancement in his plea agreement but also that recruitment into a sophisticated scheme is active leadership. The District Court concluded that the enhancement was warranted.

Bridges also asserted that the District Court should not consider any evidence related to his conduct while on pretrial release. He argued that such evidence should be considered only as it relates to the three-level sentence reduction for acceptance of responsibility , so, because the Government was not contesting whether Bridges accepted responsibility, it should not be considered at all. Bridges further argued that the Government presenting such evidence was inconsistent with its obligations under the plea agreement to recommend a sentence at the low end of the Guidelines range.

The Government responded that the evidence was relevant to the District Court’s determination of an appropriate sentence, particularly to show both that Bridges should be remanded to custody immediately and that there was no basis for a downward deviation from the Guidelines range. The Government also maintained that the plea agreement expressly allowed both parties to allocute fully at sentencing. The District Court accepted the evidence , explaining that the plea agreement was not binding as to sentencing and that sentencing is “the one inescapable task that judges cannot give to anyone else.” The Court also explained that the Government had a duty of candor to report such evidence to the Court and that, except for constitutional constraints, a district

24-11909 Opinion of the Court 5

court could consider “virtually anything a defendant has done” at sentencing. The District Court sentenced Bridges to 96 months imprisonment , followed by 5 years of supervised release. The Court explained that this deviation was necessary to achieve “the sentencing objectives of punishment, deterrence, and incapacitation” because Bridges “just continue[d] in the same conduct” after pleading guilty.

Bridges timely appeals.

II. A.

Bridges first argues that the District Court clearly erred in finding that he continued to engage in criminal conduct while on pretrial release.

We review the District Court’s findings of fact for clear error . United States v. Little, 864 F.3d 1283, 1290 (11th Cir. 2017) (citation omitted). “For a factual finding to be clearly erroneous, this court, after reviewing all of the evidence, must be left with a definite and firm conviction that a mistake has been committed.” Id. (citation and internal quotation marks omitted).

“When a defendant challenges one of the factual bases of his sentence . . . the Government has the burden of establishing the disputed fact by a preponderance of the evidence.” United States v. Sepulveda, 115 F.3d 882, 890 (11th Cir. 1997) (citation and internal quotation marks omitted). This burden is met when the court finds, based on evidence bearing some indicia of reliability, that the

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existence of a fact is more probable than its nonexistence. United States v. Trainor, 376 F.3d 1325, 1331 (11th Cir. 2004).

The District Court’s finding that Bridges continued his criminal conduct while on pretrial release is supported by multiple sources of reliable evidence. Bridges’s fingerprint was found on one of the altered checks, and messages from an iCloud account bearing his name discussed fraudulent check activities. The check was altered and the messages were sent while Bridges was on pretrial release. Taken together, this evidence supports the District Court’s finding of Bridges’s continued criminal conduct by more than a preponderance . The District Court did not clearly err.

B.

Bridges next argues that the Government breached his plea agreement by informing the District Court of his continued criminal conduct while on pretrial release. Bridges maintains that the Government’s disclosure of that information was inconsistent with its simultaneous recommendation of a sentence on the low end of the Guidelines range and was, thus, a breach of his plea agreement.

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