United States v. Shefiu Animashaun Hanson, 124 F.4th 1013

Shefiu A. Hanson pled guilty to wire fraud and conspiracy after operating a scheme that defrauded at least 30 victim businesses out of $1,122,805.74 through fake accounts and fraudulent invoices.
Hanson was sentenced in May 2023 to 46 months’ imprisonment with no prior criminal history.
Hanson sought a sentence reduction under 18 U.S.C. § 3582(c)(2) and the retroactive U.S.S.G. § 4C1.1, which allows certain first-time offenders a sentencing benefit.
The district court denied the motion, finding that Hanson caused “substantial financial hardship” to victims, rendering him ineligible for the reduction.
On appeal, Hanson contested that the harm suffered by his victims did not constitute "substantial financial hardship" under the Guidelines and that the lower court failed to make individualized hardship findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility under § 4C1.1 based on "substantial financial hardship"	Harm to victims was not “substantial” under the guidelines; the court relied on generalized, not individualized, findings	Hanson’s conduct met the threshold for substantial financial hardship, including specific harms to individual victims	Application note list is non-exhaustive; district court's findings on substantial hardship were not clearly erroneous

Dillon v. United States, 560 U.S. 817 (2010) (describes the two-step process for sentence reductions under retroactive guidelines)
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (outlines process for determining sentence modification eligibility)
United States v. Curry, 606 F.3d 323 (6th Cir. 2010) (standard of review for eligibility and ultimate sentencing decision)
United States v. May, 568 F.3d 597 (6th Cir. 2009) (reviews factual findings for clear error)
United States v. Minhas, 850 F.3d 873 (7th Cir. 2017) (financial hardship must be evaluated relative to each victim)