United States v. Makeshia Glover, 16-4183

Five defendants (Jefford and Linda Henry, their children Jeffrey Henry and Makeshia Glover, and friend Bobby McGuire) were convicted by jury of conspiracy to commit mail, wire, and bank fraud; mail fraud; wire fraud; false claims; and conspiracy to commit money laundering.
All defendants initially elected to proceed pro se and filed repeated frivolous motions invoking “sovereign citizen” theories and otherwise engaged in disruptive, obstructionist conduct during pretrial proceedings.
The district court revoked their pro se status before trial and appointed counsel after continued frivolous filings, refusals to review discovery, and disruptive behavior at pretrial conferences and after jury selection.
Jefford and Linda Henry moved for judgment of acquittal on multiple mail fraud counts alleging that mailing checks drawn on a closed account did not deprive creditors of property because debts remained enforceable; the court denied the motions.
Makeshia Glover challenged the district court’s attribution to her of an intended-loss amount at sentencing, arguing the court failed to make a specific finding on when she joined the conspiracy and thus included pre‑participation losses.
The Fourth Circuit affirmed: (1) revocation of pro se status was proper due to obstructionist conduct, (2) sufficient evidence supported denial of acquittal on mail fraud counts, and (3) the loss calculation for Glover was a reasonable estimate supported by evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court violated the Sixth Amendment by revoking pro se status	Defendants: revocation improperly denied right to self-representation	Court/Appellee: revocation justified by repeated obstruction, frivolous filings, and refusal to cooperate	Affirmed — revocation proper where conduct was deliberately obstructionist
Whether mail fraud convictions (Counts 2–5, 7–9) should be vacated for lack of deprivation of property	Henrys: checks from closed account did not deprive creditors because debts remained unsatisfied and creditors retained remedies	Government: scheme intended to extinguish creditors’ property interests; success not required	Affirmed — sufficient evidence of intent and use of mails in furtherance of scheme
Whether the mail fraud statute requires actual victim loss to sustain conviction	Henrys: reliance on Adler — no property interest, so acquittal required	Government: mail fraud penalizes use of mails in executing scheme; actual success not required	Court: actual harm not required; mailing in furtherance of scheme suffices
Whether the district court erred in attributing loss to Glover for pre‑joining conduct	Glover: court failed to find when she joined; loss included conduct before she joined	Government: evidence supports she joined by Dec 2012; loss estimate reasonable	Affirmed — district court’s loss estimate not clearly erroneous; supported by trial evidence

Faretta v. California, 422 U.S. 806 (recognizes Sixth Amendment right to self-representation)
Indiana v. Edwards, 554 U.S. 164 (right to self-representation is not absolute)
United States v. Bush, 404 F.3d 263 (government interest can outweigh self-representation when necessary for trial integrity)
United States v. Bollin, 264 F.3d 391 (mail fraud does not require proof that scheme actually defrauded victims)
United States v. Gillion, 704 F.3d 284 (elements of mail fraud: scheme and use of mails)
United States v. Wynn, 684 F.3d 473 (specific intent element for fraud requires intent to deprive something of value)
United States v. Jaensch, 665 F.3d 83 (standard of review for Rule 29 motions)
United States v. Allmendinger, 706 F.3d 330 (clear‑error review of loss amount at sentencing)
United States v. Cloud, 680 F.3d 396 (district court need only make a reasonable estimate of loss for Guidelines calculation)
United States v. Miller, 316 F.3d 495 (preponderance standard and reasonable loss estimation for sentencing)