United States v. Bobo, 4:23-cr-00578

Defendant Connie Bobo was indicted for wire fraud, aggravated identity theft, and obstruction of justice related to an alleged multi-million dollar fraud scheme diverting funds meant for feeding low-income children.
After initial release on a personal recognizance bond with conditions, Bobo’s conditions were modified to prohibit any access to third-party financial or identifying information at her daycare business and to inform clients about her criminal case.
Subsequent violations were reported, including Bobo’s continued involvement in the daycare business and its finances, leading to a further restriction barring employment or involvement in daycare operations.
The government moved to revoke Bobo’s bond after she admitted to ongoing involvement with the daycare; the Court granted the motion, citing repeated violations and inability to comply with release conditions.
Bobo moved for reconsideration, arguing her violations were transitional and that she was now fully compliant, not a flight risk, and not a danger to the community; the government opposed, citing repeated noncompliance and continued risk.
The Court denied the motion for reconsideration, citing ample evidence of repeated violations, risk to the community, and likelihood of flight.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bobo violated release conditions	Bobo repeatedly involved in daycare finance, admitted so	Any violations due to transitional period post-business sale	Court found clear/convincing evidence of multiple violations
Whether Bobo is likely to comply if released	Past conduct proves unlikelihood of future compliance	She can now comply, transition is over	Court found unlikely to abide by any release conditions
Whether Bobo is a flight risk	Serious charges, risk of lengthy prison term, hidden funds	Strong community ties, no prior record; not a flight risk	Court found Bobo is a flight risk
Whether Bobo is a danger to community	Extensive fraud and continued deception during investigation	Nonviolent charges, service record, no risk to community	Court found Bobo remains a danger to the community

United States v. Cook, 87 F.4th 920 (8th Cir. 2023) (potential lengthy sentence and lack of prior prison time create risk of flight)
United States v. Giordano, 370 F. Supp. 2d 1256 (S.D. Fla. 2005) (factors for finding serious risk of flight include avoiding arrest and hidden assets)