USA v. Paul Wilson

2012 DNH 143
CourtDistrict Court, D. New Hampshire
DecidedAugust 23, 2012
DocketCriminal No. 11-cr-83-JL
StatusPublished

This text of 2012 DNH 143 (USA v. Paul Wilson) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v. Paul Wilson, 2012 DNH 143 (D.N.H. 2012).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America v. Criminal N o . 11-cr-83-JL Opinion N o . 2012 DNH 143 Paul Wilson

MEMORANDUM ORDER

This case involves the application of § 3B1.3 of the United

States Sentencing Guidelines, specifically, whether § 3B1.3

requires the defendant be in a position of trust vis-à-vis his or

her victim. Defendant Paul Wilson, a former employee of Goss

International Americas, Inc. (“Goss”), pleaded guilty to three

counts of wire fraud in violation of 18 U.S.C. § 1343. In its

Presentence Investigation Report (“PSR”), the United States

Probation Office recommended that a two-level increase be applied

to Wilson’s base offense level pursuant to § 3B1.3 for abusing a

position of trust at Goss. Both the defendant and the government

have objected to this two-level enhancement, arguing that Wilson

was not in a “trust relationship” with his victims.

As discussed in more detail below, neither the plain language of § 3B1.3 nor its official commentary requires the defendant to be in a position of trust vis-à-vis his or her victim in order for the adjustment to apply. It is true that some courts in other circuits have created a “relationship with the victim” prerequisite to § 3B1.3’s applicability, citing the “intent” underlying the Guideline. Our Court of Appeals has never done s o , however, and has strongly implied (if not conclusively held) that such a prerequisite does not exist. In any event, because the language of the guideline itself unambiguously does not require such a relationship, judicial effort to ascertain the intent behind the Guideline is neither necessary nor appropriate. See, e.g., United States v . Luna- Díaz, 222 F.3d 1 , 3 (1st Cir. 2000). Because Wilson “abused a position of public or private trust . . . in a manner that significantly facilitated the commission or concealment of the offense,” U . S . SENTENCING GUIDELINES MANUAL (“U.S.S.G.”) § 3B1.3 (2011 ) , the court concludes that a two-level enhancement pursuant to § 3B1.3 is appropriate in this case.

I. Applicable legal standard

“[A]lthough they are not statutes, [the sentencing

guidelines] are to be construed in much the same fashion.”

United States v . DeLuca, 17 F.3d 6, 10 (1st Cir. 1994). A

sentencing court “begin[s], as with other questions of statutory

and regulatory interpretation, with the plain language of the

disputed guideline.” Luna-Díaz, 222 F.3d at 3 ; see also United

States v . Guevara-Lopez, 92 F.3d 1169 (1st Cir. 1996)

(“[C]onstruction of the relevant guideline section should begin

by looking at the language of the law and by examining the

ordinary, contemporary, common meaning of the words.”). Where

there is ambiguity in a guideline’s language, the Court of

Appeals has endorsed the use of external aids as a guide to

discerning the meaning of the guideline. For example, “the

Sentencing Commission’s commentary and application notes are

given substantial weight.” United States v . Thongsophaporn, 503

F.3d 5 1 , 58 n.7 (1st Cir. 2007). Under First Circuit case law,

the sentencing court may also “refer[] to pre-guidelines

precedent,” United States v . O’Neil, 11 F.3d 2 9 2 , 298 (1st Cir.

2 1993), and “the purposes and underlying policy” of the guideline,

Guevara-Lopez, 92 F.3d at 1169.

Once the court has determined the meaning of the guideline,

it must decide whether a preponderance of the evidence supports

its application. United States v . Sicher, 576 F.3d 6 4 , 70 (1st

Cir. 2009). The evidence “must be viewed as a whole and not

atomized.” Id. at 7 1 . The court may rely on facts set forth in

the PSR, and, though the defendant may object to those facts, “if

his objections to the PSR are merely rhetorical and unsupported

by countervailing proof, the district court is entitled to rely

on the facts in the PSR.” United States v . Prochner, 417 F.3d

5 4 , 65-66 (1st Cir. 2005) (internal alterations omitted). The

court is also “entitled to rely on circumstantial evidence, and

draw plausible inferences therefrom.” United States v . Cannon,

589 F.3d 5 1 4 , 517 (1st Cir. 2009).

II. Background

From 1999 to February 2008, Wilson was employed as the

International Trade Finance Manager at Goss in Durham, New

Hampshire. Goss manufactures large commercial printing presses,

which it sells both domestically and internationally. When

conducting international sales, Goss utilized the Export-Import

Bank, or “Ex-Im.” Ex-Im is an independent agency of the United

States that provides insurance and guarantees on loans to aid

3 foreign buyers in the purchase of U.S. goods, with the goal of

promoting exports.

In his capacity as International Trade Finance Manager,

Wilson was responsible for obtaining information about the

financial status of foreign buyers of Goss’s printing presses,

and submitting that information to Ex-Im in connection with

Goss’s applications for credit insurance. After Ex-Im insured

Goss’s loans to its foreign buyers, Goss would sell the loans to

other lenders. Wilson was also involved in Goss’s sales of these

loans. Through this work, Wilson came into contact with James

Bender, a Senior Vice President at Sovereign Bank in Boston.

In the mid-2000s, Wilson and Bender incorporated two

entities--Zephyr Capital, LLC and Zephyr Financial, LLC

(collectively, “Zephyr”)–-which purportedly offered international

sales advice and services. On four separate occasions between

2006 and 2008, Wilson and Bender used their positions at Goss and

Sovereign to bill Goss customers for work that Zephyr had not

actually performed. Wilson used his position at Goss to lead

these customers to believe that Goss had engaged Zephyr to

perform this work. By way of example, Wilson sent one customer a

letter (on Goss letterhead and signed in his capacity as finance

manager) stating that “we are working with Zephyr Capital to

obtain EXIM approval” and “[b]oth Zephyr Capital and myself are

very confident the transaction shall be approved.”

4 On three of these four occasions, the customers paid the

invoices via wire transfers to Zephyr’s bank account. On the

fourth occasion, after Wilson had left Goss, the intended victim

contacted Wilson’s successor at Goss, who uncovered Wilson’s and

Bender’s scheme.

III. Analysis

Section 3B1.3 of the United States Sentencing Guidelines

provides that “[i]f the defendant abused a position of public or

private trust . . . in a manner that significantly facilitated

the commission or concealment of the offense,” the defendant’s

base offense level must be increased by 2 levels. U.S.S.G. §

3B1.3 (2011). Wilson argues that in order for this enhancement

to apply, “there must be a trust relationship between the

Defendant and the victims,” as “analyzed from the perspective of

the victims.” Deft.’s O b j . to PSR (document n o . 29) at 1 (citing

United States v . Moore, 29 F.3d 175 (4th Cir. 1994); United

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2012 DNH 143, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usa-v-paul-wilson-nhd-2012.