United States v. Zsa Zsa Couch

Court of Appeals for the Eleventh Circuit·Decided November 18, 2025·No. 24-10313·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-10313

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

ZSA ZSA BOUVIER COUCH, Defendant-Appellant.

Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 2:21-cr-00185-KKD-CWB-1

Before BRANCH, LUCK, and ANDERSON, Circuit Judges. PER CURIAM:

A jury found Zsa Zsa Couch guilty of five counts of bank fraud, six counts of making a false statement to a federally insured bank, and two counts of money laundering after she fraudulently

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obtained government-backed loans through the Paycheck Protection Program. Couch appeals her convictions on the bank fraud and money laundering counts only, arguing that the district court erred when it denied her motion for a judgment of acquittal because the government failed to present sufficient evidence at trial that any “financial institution” was the victim of her fraud scheme. Because we conclude that the government presented sufficient evidence for a reasonable jury to conclude that at least two federally insured financial institutions had custody or control over program funds that Couch fraudulently obtained, we affirm.

FACTUAL BACKGROUND

In 2020, in response to the Covid-19 pandemic, Congress enacted the Coronavirus Aid, Relief, and Economic Security Act to fund the Paycheck Protection Program to provide economic relief to small businesses. Under the program, lenders—primarily banks—made loans to qualified business owners to help them stay in business. Program funds were restricted to payroll costs, mortgage interest, rent, utilities, and other expenses, and the applicant’s average payroll expenses determined the amount of the loan. To obtain a program loan, the applicant had to submit a loan application , which required listing the business’s average monthly payroll expenses and number of employees; certifying that the information was true and accurate; acknowledging that making a false statement on the application was a crime; and providing supporting tax documents. The Small Business Administration oversaw the program and provided a “100 percent guarantee of the loan.” If the

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loan proceeds were used appropriately, the Administration would forgive or reimburse the lender for the loan.

Couch applied to Trustmark National Bank and Regions Bank for program loans for several businesses, including Trinity Christian Ministries, Kidz Academy Christian Child Care Center, Slim Fit Weight Loss Medical Clinic, and Bouvier Hair Boutique. Couch received five program loans from the two banks totaling $609,687.47.

PROCEDURAL HISTORY

On April 7, 2021, a federal grand jury indicted Couch for five counts of bank fraud, in violation of 18 U.S.C. sections 2 and 1344(2) (counts one through five); six counts of making a false statement to a federally insured bank, in violation of 18 U.S.C. sections 2 and 1014 (counts six through eleven); and two counts of money laundering, in violation of 18 U.S.C. sections 2 and 1957(a) (counts twelve through thirteen). In counts one through five, the government alleged that Couch committed bank fraud to get five program loans by providing false financial information to two federally insured financial institutions, allowing her to access money “owned by and under the custody and control” of the banks. In counts six through eleven, the government alleged that Couch had made false representations to Trustmark and Regions concerning the number of people she employed, her average monthly payroll, and tax information related to the businesses. In counts twelve and thirteen, the government alleged that Couch committed two counts of money laundering by using the fraudulently procured program

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funds to purchase an Audi and a Mercedes-Benz. Couch proceeded to trial.

After the government rested, she moved for a judgment of acquittal on the bank fraud and money laundering counts. In her motion, Couch argued that the money laundering counts were “dependent upon” the bank fraud counts; that the government’s evidence proved that the program funds came from the Administration instead of a financial institution; and that because the Administration is not a financial institution, as defined in 18 U.S.C. section 20, the government had not produced sufficient evidence for the jury to find her guilty of the bank fraud and money laundering . The district court denied the motion, and the jury returned a guilty verdict on all thirteen counts. On January 16, 2024, the district court sentenced Couch to forty-five months’ imprisonment followed by three years’ supervised release and ordered $690,687.47 in restitution.

Couch timely appealed.

STANDARD OF REVIEW

We review de novo the denial of a motion for a judgment of acquittal. United States v. Bowman, 302 F.3d 1228, 1237 (11th Cir. 2002) (citing United States v. Perez-Tosta, 36 F.3d 1552, 1556 (11th Cir. 1994)). “When the motion raises a challenge to the sufficiency of the evidence, we review the sufficiency of the evidence de novo, drawing all reasonable inferences in the Government’s favor.” Id. (footnote omitted) (citing Perez-Tosta, 36 F.3d at 1556). “We will refuse to overturn a conviction ‘if any reasonable construction of

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the evidence would have allowed the jury to find the defendant guilty beyond a reasonable doubt.’” United States v. Schreck, 130 F.4th 1297, 1301 (11th Cir. 2025) (quoting United States v. Grow, 977 F.3d 1310, 1320 (11th Cir. 2020)). We review de novo matters of statutory interpretation. Id. (citing United States v. Shamsid-Deen, 61 F.4th 935, 946 (11th Cir. 2023)).

DISCUSSION

The sole issue for us to decide is whether the district court erred in denying Couch’s motion for a judgment of acquittal as to the five bank fraud counts and the two money laundering counts. Framing her argument “as one challenging the sufficiency of the evidence supporting h[er] convictions,” id. (citing United States v. Williams, 790 F.3d 1240, 1244 (11th Cir. 2015)), Couch doesn’t dispute that Trustmark and Regions are financial institutions, arguing instead that the Administration, as the ultimate guarantor of the program funds, was the actual victim of her scheme. According to Couch, because the Administration “does not meet the criteria of a financial institution, bank fraud was not established, and, in turn, money laundering was not established.” In other words, “this appeal turns on matters of statutory interpretation, as [Couch] argues that, under the ‘correct’ interpretation of the relevant criminal statute , the government failed to offer sufficient evidence to convict h[er].” See id. (alteration adopted and internal quotation marks omitted) (quoting Williams, 790 F.3d at 1244). Thus, “[t]o determine whether sufficient evidence supports [Couch’s] convictions, we must interpret the text of the governing statute[s], . . . against the evidentiary record.” See id. “Under principles of statutory

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interpretation, ‘we look to the plain and ordinary meaning of the statutory language as it was understood at the time the law was enacted.’” Id. at 1302 (quoting United States v. Chinchilla, 987 F.3d 1303, 1308 (11th Cir. 2021)).

We first address Couch’s argument that she is entitled to a judgment of acquittal on the bank fraud counts before briefly addressing her argument as to the money laundering counts.

The bank fraud counts

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