United States v. Carl Palladinetti, 16 F.4th 545

Palladinetti participated in a multi‑year mortgage‑fraud scheme that purchased apartment buildings and resold units as condominiums; he acted as attorney and registered agent for entities used in the scheme.
A 16‑count indictment charged him with seven counts of bank fraud and nine counts of making false statements; the government agreed to dismiss other counts if he were convicted on count one (a $345,000 Washington Mutual mortgage dated July 14, 2005).
Palladinetti stipulated to facts establishing almost all elements of 18 U.S.C. § 1344(1) except whether the lender’s deposits were FDIC‑insured on the mortgage date; the bench trial therefore focused solely on FDIC insurance status.
The government introduced FDIC certificates (showing institution number 32633), a 2005 amended 10‑K, OTS succession/name‑change correspondence, the recorded mortgage and riders (naming “Washington Mutual Bank, FA”), HUD‑1s, and testimony from a Washington Mutual underwriter and an FDIC employee confirming continuous insurance and use of both corporate and "FA" names.
District court found the lender’s deposits were FDIC‑insured on July 14, 2005, and convicted Palladinetti of bank fraud; he appealed, arguing insufficient evidence that the defrauded institution was FDIC‑insured.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lender’s deposits were FDIC‑insured on July 14, 2005	FDIC certificates, 10‑K, OTS letters, and witness testimony show one continuous institution (inst. no. 32633) that did business as both “Washington Mutual Bank” and “Washington Mutual Bank, FA,” and was insured	Name variance ("Bank" v. "Bank, FA") creates doubt that the actual defrauded entity was FDIC‑insured	Affirmed: evidence supported continuous FDIC insurance and that the lender named on the loan was the insured entity
Whether Alexander (8th Cir.) requires vacatur where names differ	Government: Alexander is distinguishable because here documentary and testimonial evidence tied the exact lender to the FDIC‑insured institution	Palladinetti: Alexander suggests similar names alone are insufficient to prove insurance	Affirmed: court distinguished Alexander given the record showing a single insured entity that did business under both names

United States v. O'Leary, 957 F.3d 731 (7th Cir. 2020) (bench‑trial sufficiency standard applies as in jury trials)
United States v. Angle, 234 F.3d 326 (7th Cir. 2000) (describes difficulty of overturning sufficiency challenges)
United States v. Grayson Enters., Inc., 950 F.3d 386 (7th Cir. 2020) (characterizes burden as nearly insurmountable)
United States v. Ginsberg, 971 F.3d 689 (7th Cir. 2020) (review standard: view evidence in light most favorable to government)
United States v. Orlando, 819 F.3d 1016 (7th Cir. 2016) (same sufficiency principles)
United States v. Friedman, 971 F.3d 700 (7th Cir. 2020) (elements of bank fraud under 18 U.S.C. § 1344)
United States v. Alexander, 679 F.3d 721 (8th Cir. 2012) (similar‑name institutions insufficient to prove FDIC insurance where no evidence of continuity)