United States v. Rondell Scott Hedrick
663 F. App'x 788
| 11th Cir. | 2016Background
- Indictment charged Rondell Hedrick with wire fraud under 18 U.S.C. § 1343 for operating a website and soliciting a $500,000 gold investment through false representations.
- Hedrick allegedly told a Confidential Source (CS) he regularly bought large quantities of gold and had international contacts, banks, licenses, planes, and people on the ground—statements later shown to be false.
- Hedrick communicated with the CS by phone and email and provided documents (Promissory Note, Purchase and Sale Agreement) to close the deal; law enforcement arrested him at a hotel meeting.
- At trial, Hedrick moved under Federal Rule of Criminal Procedure 29 for judgment of acquittal twice (after the government’s case-in-chief and at trial’s end); both motions were denied.
- The jury found Hedrick guilty; on appeal he argued insufficiency of the evidence, claiming lack of fraud and lack of intent to defraud.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove wire fraud (scheme to defraud + use of interstate wires) | Government: misrepresentations were material and used interstate communications to execute scheme; evidence supports intent to defraud | Hedrick: though he used wires, there was no fraud or intent to defraud—he intended to complete the investment | Affirmed. Sufficient evidence of material misrepresentations and intent; conviction stands |
Key Cases Cited
- United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (standard for reviewing sufficiency of evidence in criminal cases)
- United States v. Langford, 647 F.3d 1309 (11th Cir. 2011) (elements of wire fraud require scheme to defraud and use of interstate wires)
- United States v. Hasson, 333 F.3d 1264 (11th Cir. 2003) (material misrepresentations and omissions for fraud)
- United States v. Svete, 556 F.3d 1157 (11th Cir. 2009) (mail/wire fraud covers any scheme to defraud regardless of fanciful nature or ordinary prudence of reliance)
- Neder v. United States, 527 U.S. 1 (1999) (definition of materiality in fraud offenses)