United States v. Randall Causey, 748 F.3d 310

Causey participated in a Gary, Indiana mortgage fraud conspiracy (2005–06) involving coworkers Chandler and Rainey and others.
He was convicted at a five-day trial on wire fraud and conspiracy charges; others pled guilty.
The scheme recruited novice buyers, falsified applications and documents, inflated appraisals, and netted illicit closing proceeds.
Chandler and Rainey ran the core operations; Causey recruited buyers and handled fraudulent paperwork.
After trial, the district court imposed a two-level enhancement for Causey’s leadership role; he challenges evidentiary rulings and the enhancement.
The government introduced numerous photographs of properties to illustrate context and attempted to prove intent and scheme scope through various witnesses and transactions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of photographs of houses after the conspiracy	Causey argues photos are irrelevant/prejudicial	Government contends photos aid lay understanding and are properly timely, with precautions	No abuse; photos admissible and probative with safeguards
Admission of the Dudley transaction under Rule 404(b)	Causey contends it shows bad character unrelated to charged acts	Government shows motive/intent/knowledge related to the conspiracy	Admissible; sufficiently similar and probative of intent/knowledge
Kvachkoff’s expert testimony barred for lack of Rule 16 disclosure	Causey asserts no disclosure, so exclusion is error	Kvachkoff testimony became expert and undisclosed; exclusion proper	Proper; exclusion affirmed
Chandler’s expert testimony and 400% market estimate	Chandler not qualified; 400% estimate exceeded disclosure scope	Testimony was harmless and did not affect outcome	Harmless error; no reversal for this evidentiary ruling
Two-level enhancement under § 3B1.1(c) for organizer/leader	Causey argues he was a minor participant	Government proves leadership, recruitment, control over others	Properly applied; Causey recruited buyers and exerted control over participants

Thompson v. City of Chicago, 472 F.3d 444 (7th Cir. 2006) (evidence need not be decisive to be admissible; relevance and probative value)
Cheek v. United States, 740 F.3d 440 (7th Cir. 2014) (plain error and harmless-error standards; notes on admission and limiting instructions)
York v. United States, 572 F.3d 415 (7th Cir. 2009) (harmless error standard for evidentiary rulings in trial)
Miller v. United States, 673 F.3d 688 (7th Cir. 2012) (probative value of evidence and defense impact on intent considerations)
Reese v. United States, 666 F.3d 1007 (7th Cir. 2012) (rule 404(b) intent/knowledge and similarity requirements)