United States v. Wilkin De Los Santos

CourtCourt of Appeals for the Second Circuit
DecidedJune 18, 2024
Docket22-3164
StatusUnpublished

This text of United States v. Wilkin De Los Santos (United States v. Wilkin De Los Santos) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second 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. Wilkin De Los Santos, (2d Cir. 2024).

Opinion

22-3164 United States of America v. Wilkin De Los Santos

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

1 At a stated term of the United States Court of Appeals for the Second Circuit, held at the 2 Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3 18th day of June, two thousand twenty-four. 4 5 PRESENT: 6 GERARD E. LYNCH, 7 MYRNA PÉREZ, 8 MARIA ARAÚJO KAHN, 9 Circuit Judges. 10 _____________________________________ 11 12 UNITED STATES OF AMERICA, 13 14 Appellee, 15 16 v. No. 22-3164

17 WILKIN DE LOS SANTOS, a/k/a SEP 550,

18 Defendant-Appellant. *

19 _______________________________________

20 21 22 23 24

* The Clerk of Court is respectfully directed to amend the official caption as set forth above.

1 1 FOR APPELLEE: EDWARD C. ROBINSON JR. (Matthew R. 2 Shahabian, James Ligtenberg, on the brief), 3 Assistant United States Attorneys for Damian 4 Williams, United States Attorney for the 5 Southern District of New York, New York, NY. 6 7 FOR DEFENDANT-APPELLANT: PETER J. TOMAO, Law Office of Peter J. Tomao, 8 Garden City, NY. 9 10 Appeal from a judgment of the United States District Court for the Southern District of

11 New York (Torres, J.).

12 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

13 DECREED that the judgment, dated December 6, 2022, of the district court is AFFIRMED.

14 Defendant-Appellant Wilkin De Los Santos was found guilty by a jury of three counts,

15 only one of which he appeals. Relevant here, De Los Santos appeals his conviction for aggravated

16 identity theft under 18 U.S.C. § 1028A(a)(1), arguing that the government failed to establish with

17 sufficient evidence that he met the knowledge requirement of the statute.

18 We assume the parties’ familiarity with the procedural history of the case, the issues on

19 appeal, and the underlying facts, which we reference only as necessary to explain our decision to

20 affirm the judgment.

21 I. STANDARD

22 “We review de novo a challenge to the sufficiency of the evidence supporting a defendant’s

23 conviction.” United States v. Krivoi, 80 F.4th 142, 155 (2d Cir. 2023). However, “a defendant

24 mounting such a challenge ‘bears a heavy burden[.]’” United States v. Harvey, 746 F.3d 87, 89

25 (2d Cir. 2014) (per curiam) (quoting United States v. Heras, 609 F.3d 101, 105 (2d Cir. 2010)). A

26 reviewing court must sustain the jury’s guilty verdict if, “after viewing the evidence in the light

27 most favorable to the prosecution, any rational trier of fact could have found the essential elements

28 of the crime beyond a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319 (1979). “The

2 1 jury may reach its verdict based upon inferences drawn from circumstantial evidence.” United

2 States v. Persico, 645 F.3d 85, 104 (2d Cir. 2011) (internal quotation marks omitted). We will

3 reverse a guilty verdict only if we conclude that “no reasonable jury could find guilt beyond a

4 reasonable doubt” based on the totality of the evidence. Heras, 609 F.3d at 105–06.

5 II. DISCUSSION

6 Under 18 U.S.C. § 1028A(a)(1), a conviction for aggravated identity theft requires proof

7 “that the defendant knew that the means of identification at issue belonged to another person.”

8 Flores-Figueroa v. United States, 556 U.S. 646, 657 (2009). 1 De Los Santos incorrectly argues

9 that the government failed to introduce sufficient evidence at trial to prove that he possessed such

10 knowledge.

11 At the outset, the Supreme Court has explained that, “in the classic case of identity theft,

12 intent is generally not difficult to prove. For example, where a defendant has used another person’s

13 identification information to get access to that person’s bank account, the Government can prove

14 knowledge with little difficulty.” Id. at 656.

15 The government presented sufficient evidence that De Los Santos knew he and his

16 coconspirators were exploiting real persons’ personal identification to gain access to their

17 telephone accounts to fraudulently obtain cellphones. Among others, the jury heard at least two

18 categories of testimony: descriptions of the scheme which necessarily required using the identities

19 of real people to access their telephone accounts; and victim statements.

20 First, the government introduced testimony from a cooperating witness, who worked as a

21 straw purchaser of the phones on behalf of De Los Santos, and a lead investigator from AT&T,

1 An aiding-and-abetting theory of aggravated identity theft would also support a conviction. See 18 U.S.C. §§ 1028A(a)(1), 2. A conviction for aiding and abetting aggravated identity theft requires proof that a defendant willfully caused another person to use someone else’s identification without lawful authority, knowing that the identification used belonged to someone else. See id.

3 1 who described the scheme as necessarily using the identities of real people to access their telephone

2 accounts and testified as to De Los Santos’s participation in the scheme. Specifically, the

3 cooperating witness explained that in order to fraudulently obtain cellphones, De Los Santos and

4 other members of the scheme would use their victim’s “first and last name, address, date of birth,

5 and their zip code.” Trial Tr. at 291. 2 Moreover, the cooperating witness testified that he knew

6 the remaining balance of the cellphones that would be charged to the account holder, that the

7 account holders were real “people,” and that the purchase price “all depended on the person’s

8 credit.” Id. at 281–82. The jury was entitled to infer De Los Santos’s knowledge from those facts.

9 See United States v. Holmes, 595 F.3d 1255, 1258 (11th Cir. 2010) (A reasonable jury could have

10 found that “[the defendant] would not have sought credit using [the victim’s] personal information

11 if [the defendant] were not confident that [the victim] likely had an actual credit history.”).

12 The AT&T investigator explained that a person’s personal identification had to be used in

13 order to access a person’s account to add an authorized user, who is then able to obtain a phone

14 using matching identification.

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Related

United States v. Holmes
595 F.3d 1255 (Eleventh Circuit, 2010)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Flores-Figueroa v. United States
556 U.S. 646 (Supreme Court, 2009)
United States v. Heras
609 F.3d 101 (Second Circuit, 2010)
United States v. Lewis
408 F. App'x 423 (Second Circuit, 2010)
United States v. Persico
645 F.3d 85 (Second Circuit, 2011)
United States v. Friedman
998 F.2d 53 (Second Circuit, 1993)
United States v. Ramos
677 F.3d 124 (Second Circuit, 2012)
United States v. Harvey
746 F.3d 87 (Second Circuit, 2014)
United States v. Pichardo
595 F. App'x 19 (Second Circuit, 2014)
United States v. Tomasino
885 F.3d 17 (First Circuit, 2018)
United States v. Klein
913 F.3d 73 (Second Circuit, 2019)
Dubin v. United States
599 U.S. 110 (Supreme Court, 2023)
United States v. Krivoi
80 F.4th 142 (Second Circuit, 2023)

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United States v. Wilkin De Los Santos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-wilkin-de-los-santos-ca2-2024.