UNITED STATES OF AMERICA v. TYLER N. ROSS - Articles

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Posted by: Azya Thornton on Mar 31, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Mark J. Kriger, LARENE & KRIGER, P.L.C., Detroit, Michigan, Douglas A. Berman, Dublin, Ohio, for Appellant.

Attorneys 2: ON BRIEF: Mahogane D. Reed, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Judge(s): MOORE, GIBBONS, and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

KAREN NELSON MOORE, Circuit Judge. Defendant-appellant Tyler Ross pleaded guilty to one count of conspiracy to commit an offense against the United States based on his involvement in a scheme to provide mortgage lenders with inflated income information about properties owned by his real-estate-investment firm. Ross argues that the district court erred when it applied a sentencing enhancement for defendants who “derived more than $1,000,000 in gross receipts from one or more financial institutions as a result of the[ir] offense.” U.S. Sent’g Guidelines Manual § 2B1.1(b)(17)(A) (U.S. Sent. Comm’n 2023). Because the government showed by a preponderance of the evidence that Ross’s conduct met the enhancement’s requirements, and because Ross’s contrary interpretations of the enhancement are inconsistent with the Sentencing Guideline’s text, we AFFIRM the district court’s judgment.

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