United States v. Ronald Taylor
702 F. App'x 464
| 7th Cir. | 2017Background
- Ronald Taylor filed fraudulent "Ronald Taylor Trust" federal tax returns for 2007–2009 claiming $900,000 income, $900,000 fiduciary fees, and $300,000 withheld tax per year, requesting $300,000 refunds each year.
- The trust documents showed the trust was created in April 2010, after the tax years at issue; one refund of $300,000 was issued and deposited into a trust bank account Taylor opened in 2010.
- Taylor withdrew most funds in cashier’s checks made out to himself; he was indicted for three counts of presenting false claims to the IRS (18 U.S.C. § 287) and one count of converting public funds (18 U.S.C. § 641).
- Taylor repeatedly asserted pro se, jurisdictional and Moorish-nationality defenses; the district court allowed Taylor to proceed pro se with standby counsel and denied his jurisdictional motions.
- A jury convicted Taylor on all four counts. The district court denied post-trial acquittal/new-trial motions, sentenced Taylor to concurrent 24-month terms (below guideline range), and ordered $300,000 restitution.
- Appellate counsel filed an Anders brief seeking to withdraw, arguing the appeal is frivolous; Taylor did not respond. The Seventh Circuit reviewed the limited issues raised and found no non-frivolous appellate arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| District-court jurisdiction | Government: federal courts have subject-matter jurisdiction over federal criminal offenses. | Taylor: various sovereign/Moorish-nationality and jurisdictional challenges asserted pro se. | Court: jurisdiction incontestable; jurisdictional challenges meritless. |
| Sufficiency of evidence on §287 (false claims) | Gov: returns were presented by Taylor, contained patently false information, and Taylor knew of falsity. | Taylor: claimed another prepared/submitted returns; denied knowledge of contents or mailing. | Court: evidence sufficient; reasonable jury could find all elements beyond reasonable doubt. |
| Sufficiency of evidence on §641 (conversion of public funds) | Gov: refund was obtained by false returns and deposited/withdrawn by Taylor for personal use. | Taylor: implicitly contested entitlement and knowledge. | Court: evidence supports conversion and knowledge; conviction affirmed. |
| Anders motion / counsel withdrawal | Counsel: no non-frivolous appellate issues; seeks permission to withdraw. | Taylor: no response. | Court: grants counsel’s motion to withdraw and dismisses the appeal. |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (recognizing counsel’s duty to identify non-frivolous issues when seeking to withdraw)
- United States v. Clarke, 801 F.3d 824 (7th Cir.) (false, groundless tax-return scheme)
- United States v. Benabe, 654 F.3d 753 (7th Cir.) (jurisdiction over federal offenses)
- United States v. Burke, 425 F.3d 400 (7th Cir.) (jurisdictional principles)
- United States v. Knox, 287 F.3d 667 (7th Cir.) (Anders submission duties)
- United States v. Peterson, 823 F.3d 1113 (7th Cir.) (standard for sufficiency and review of acquittal denials)
- United States v. Pribble, 127 F.3d 583 (7th Cir.) (appellate deference to jury credibility determinations)
- United States v. Chambers, 642 F.3d 588 (7th Cir.) (new-trial standard)
- United States v. Bey, 748 F.3d 774 (7th Cir.) (scope of appellate review in Anders cases)
- United States v. Wagner, 103 F.3d 551 (7th Cir.) (Anders brief sufficiency)
- United States v. Wilson, 788 F.3d 1298 (11th Cir.) (conversion conviction for deposits from false refunds)