United States v. Singh
22-2668
2d Cir.Mar 21, 2025Background
- Jasminder Singh was convicted of bank fraud and two counts of unlawful money transactions involving American Express, stemming from misuse of credit cards to make significant Apple product purchases and misrepresenting intent to repay.
- Singh orchestrated a scheme where he would make payments to free up credit, then quickly divert funds before payments cleared, leaving large outstanding balances.
- Trial evidence showed Singh used the diverted funds for personal gain and rewarded accomplices, including purchasing a car for his ex-wife.
- Singh’s defense argued there was no intent to defraud, attributing bounced payments to a customer’s nonpayment and claiming funds were used to keep his business afloat.
- Singh appealed his conviction on multiple grounds, including evidentiary issues, denial of severance, sentencing enhancements, and a special supervised release condition.
- The Second Circuit reviewed the district court’s rulings for abuse of discretion and clear error, ultimately affirming the conviction and sentence.
Issues
| Issue | Singh's Argument | Government's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence for Conviction | No intent to defraud; bounced payments due to customer nonpayment | Sufficient evidence shows fraudulent intent | Conviction affirmed |
| Admission of Co-Defendant/Employee Credit Purchases | Admission was unduly prejudicial and improper | Evidence admissible for intent, with limiting instructions | No abuse of discretion |
| Denial of Motion to Sever Trial | Joint trial prejudiced Singh; evidence and testimony unfairly linked | Joint trial appropriate; limiting instructions mitigated prejudice | No miscarriage of justice |
| Cumulative Error | Combined errors rendered trial unfair | No actual errors; any minor error was harmless | No new trial warranted |
| Sentencing (Leadership Role & Special Condition) | Sentence enhancements and employment condition were unwarranted/vague | Leadership evidence clear; employment condition justified by record | Sentence affirmed |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence: whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt)
- United States v. Landesman, 17 F.4th 298 (2d Cir. 2021) (reiterates deference owed to jury verdicts on sufficiency of evidence)
- United States v. Spinelli, 352 F.3d 48 (2d Cir. 2003) (explains rationale for joint trials of co-defendants and standard for severance)
- United States v. Lyle, 919 F.3d 716 (2d Cir. 2019) (details standards for admitting other act evidence under Rule 404(b))
- United States v. Szur, 289 F.3d 200 (2d Cir. 2002) (appellate review of sentencing enhancements for leadership role)