United States v. Meelad Dezfooli
2:22-cr-00142-RFB-DJA
| D. Nev. | Jul 14, 2025Background
- Meelad Dezfooli was convicted by a jury on charges of bank fraud, money laundering, and engaging in monetary transactions with criminally derived property, stemming from fraudulent PPP loan applications during the COVID-19 pandemic.
- The PPP loan applications were made through three Nevada businesses (Best Floors, A-Series LLC, Nevada Sales Ltd.) using false information about company operations and payroll.
- Dezfooli used the loan proceeds for personal expenditures, including luxury vehicles, real estate, casino gambling, and investments, contrary to the loan's intended purposes.
- The government provided direct and circumstantial evidence linking Dezfooli to the fraudulent loan applications and subsequent financial transactions.
- Dezfooli filed a post-trial motion seeking judgment of acquittal or a new trial, arguing insufficient evidence and lack of intent.
- The District Court denied his motion, affirming the jury’s verdict on all counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence (Bank Fraud) | Evidence overwhelmingly shows fraud and Dezfooli's direct involvement | Not enough direct evidence that Dezfooli submitted the applications | Sufficient evidence; motion denied |
| Sufficiency of evidence (Money Laundering) | Transactions were structured to conceal source of PPP funds | Lacked requisite intent to conceal or disguise funds | Sufficient circumstantial evidence; motion denied |
| Sufficiency under 18 U.S.C. § 1957 | Demonstrated Dezfooli knew transactions were over $10,000 and derived from criminal activity | Government failed to show knowledge of criminal nature of funds | Evidence supports knowledge and actions; denied |
| Motion for New Trial (Rule 33) | No miscarriage of justice; trial evidence robust | Interests of justice require a new trial due to evidentiary and credibility issues | Weighed evidence, found no miscarriage; motion denied |
Key Cases Cited
- United States v. Hernandez-Herrera, 273 F.3d 1213 (9th Cir. 2001) (standard for review of sufficiency of evidence for acquittal)
- United States v. Alarcon-Simi, 300 F.3d 1172 (9th Cir. 2002) (court does not assess witness credibility under Rule 29)
- United States v. Cordova Barajas, 360 F.3d 1037 (9th Cir. 2004) (Rule 29 motion asks if a rational juror could find guilt beyond a reasonable doubt)
- United States v. Nevils, 598 F.3d 1158 (9th Cir. 2010) (en banc) (sufficiency review requires evidence viewed in government's favor)
- United States v. Cloud, 872 F.2d 846 (9th Cir. 1989) (material misrepresentations support bank fraud conviction)
- United States v. Wilkes, 662 F.3d 524 (9th Cir. 2011) (complex transactions can support money laundering conviction)