Response to 116 Objections to Presentence Investigation Report — USA v. McCabe (Dkt. 117, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:24-cr-80103-AMC · Doc. 117 · 2025-05-30 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 24-80103-CR-CANNON 
 
UNITED STATES OF AMERICA 
 
v. 
 
DUSTIN SEAN McCABE, 
 
 
Defendant. 
______________________________________/ 
 
USA=S OMNIBUS RESPONSE TO PSI OBJECTIONS AND SENTENCING MEMO 
 
 
Over seven trial days, this Court saw evidence that included not just what happened on 
March 28 and 29, 2020, but also the Defendant’s total lack of remorse for killing M.C.G.F. That 
lack of remorse bled through not just his demeanor during the gut-wrenching testimony that it took 
to convict him but also through his own testimony in which he told lie after lie in a desperate but 
unsuccessful attempt to avoid prison. The Government said from the beginning that this case was 
fundamentally about his lies and his recklessness, and that bore out in the trial, showing that the 
final people the Defendant lied to were the jury, the Court, and perhaps himself. The June 12 
sentencing in this case is this Court’s opportunity to take this all into account to fashion a just and 
proper sentence—one that gives justice to M.C.G.F.’s family and friends, to the West Palm Beach 
scuba community, and to broader society in accordance with the sentencing factors set forth in 
Section 3553(a). 
 
Through this Response, the Government responds to the Defendant’s Objections (DE 115) 
and Addendum Objections (DE 116) to the Presentence Investigation Report (“PSI”), asking this 
Court to deny the Defendant’s Guidelines objections and to rule that the appropriate range is 63 to 
78 months in prison. From there, this Response asks the Court to sentence the Defendant to the top 
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of those Guidelines, with a 78-month sentence the only sentence that meets the Section 3553(a) 
factors in this tragic case.  
I. 
FACTUAL BACKGROUND 
The Government submitted a 10-page factual recitation of the trial case in its response to 
the Defendant’s motion for acquittal, see DE 98 at 2-11, and incorporates that by reference. 
II. 
LEGAL STANDARD 
A. Guidelines Sentencing Enhancements 
A sentencing court’s findings of fact may be based on undisputed statements in the PSI. 
United States v. Wilson, 884 F.2d 1355, 1356 (11th Cir. 1989). Where a defendant objects to the 
factual basis of his sentence, the government has the burden of establishing the disputed fact by a 
preponderance of the evidence. United States v. Sepulveda, 115 F.3d 882, 890 (11th Cir. 1997). If 
no party objects to allegations of fact contained in a PSI, the fact is admitted for sentencing 
purposes. United States v. Wade, 458 F.3d 1273, 1277 (11th Cir. 2006). Furthermore, objections 
to facts in the PSI “must be asserted with specificity and clarity … [o]therwise, the objection is 
waived.” United States v. Bennett, 472 F.3d 825, 832 (11th Cir. 2006); United States v. Aleman, 
832 F.2d 142, 145 (11th Cir. 1987). Vague assertions of inaccuracies are not enough to raise a 
factual dispute. United States v. Ramirez-Flores, 743 F.3d 816, 824 (11th Cir. 2014); United States 
v. Shelton, 400 F.3d 1325, 1330 (11th Cir. 2005); United States v. Norris, 50 F.3d 959, 962 (11th 
Cir. 1995). “This requirement is not gratuitous; rather, it ensures that the government has an 
opportunity to address or correct the alleged error.” Id. If a defendant fails to object, the burden 
does not shift to the government to prove the disputed facts. Bennett, 472 F.3d at 832 (“Where a 
defendant objects to the factual basis of his sentence, the government has the burden of establishing 
the disputed fact. ... Otherwise, the objection is waived.”). 
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B. This Court’s Authority to Fashion an Appropriate Sentence 
While the Sentencing Guidelines were once mandatory, the Supreme Court changed the 
sentencing landscape in United States v. Booker, 543 U.S. 220 (2005), by “invalidat[ing] the 
mandatory features of the Guidelines.” Irizarry v. United States, 553 U.S. 708, 713 (2008). With 
Booker as the law of the land, courts entered the era of “advisory Guidelines,” where picking “a 
sentence outside the Guidelines carries no presumption of unreasonableness.” Id. at 713-14 (citing 
Gall v. United States, 552 U.S. 38, 51 (2007)). So now, instead of rotely choosing a Guidelines 
sentence, the Court must also assess whether a sentence is reasonable under the 18 U.S.C. 
§ 3553(a) factors and “the totality of the circumstances.” Id.; see also United States v. Irey, 612 
F.3d 1160, 1189-90 (11th Cir. 2010) (en banc).  
That framework means that the Court’s sentence “should fit the offender and not merely 
the crime.” Pepper v. United States, 562 U.S. 476, 487 (2011). To that end, a district court should 
impose a prison term that is “sufficient, but not greater than necessary, to comply with the 
purposes” of sentencing. 18 U.S.C. § 3553. The “purposes of sentencing” under 18 U.S.C. 
§ 3553(a) include (1) “the nature and circumstances of the offense,” (2) “the seriousness of the 
offense, to promote respect for the law, and to provide just punishment for the offense,” (3) “to 
afford adequate deterrence to criminal conduct,” and (4) “to protect the public from further crimes 
of the defendant.” A sentence only runs afoul of that mandate if it “lies outside the range of 
reasonable sentences dictated by the facts.” Irey, 612 F.3d at 1190 (quotations omitted). In 
assessing those facts, “[t]he weight to be accorded any given § 3553(a) factor is a matter committed 
to the sound discretion of the district court, and the court is permitted to attach great weight to one 
factor over others.” United States v. Riley, 995 F.3d 1272, 1279 (11th Cir. 2021) (cleaned up). 
Indeed, “[t]hat is what discretion in weighing factors is about,” id., and “discretion in weighing 
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sentencing factors is particularly pronounced when it comes to weighing criminal history,” id. A 
court levies an unreasonable sentence only when it “(1) fails to afford consideration to relevant 
factors that were due significant weight, (2) gives significant weight to an improper or irrelevant 
factor, or (3) commits a clear error of judgment.” Id. at 1189 (quotations omitted). 
III. 
ARGUMENT 
 
The Defendant’s Objections borrow a page from his testimony at trial: he contests virtually 
everything but leaves the law out of it. Through this Response, the Government brings the law to 
bear, showing that the Defendant’s many Guidelines- and restitution-related objections are without 
merit. After doing so, the Government sets forth three reasons that this Court should sentence the 
Defendant to 78 months in prison, the top of his advisory Guidelines range: (1) the extreme 
recklessness of his conduct, (2) the unrelenting, brazen lies he chose to tell from the witness stand, 
and (3) his crimes of conviction that are not accounted for in the Guidelines score. Each of these 
factors show why the Defendant’s Guidelines range is appropriate and why he should receive the 
highest possible sentence within it. 
A. The Defendant’s Guidelines-Related PSI Objections are Meritless. 
 
This Court should deny the Defendant’s Guidelines-related objections because, as the 
following explains, they have no grounding in the facts presented at trial.  
1. Initial Objections, DE 115 
The following responds to the initial objections set forth at Docket Entry 115: 
 
“Objection 1: Language Implying Direct Causation of Death.” The defense now contests 
that his negligence caused M.C.G.F.’s death, Obj. at 1, but that causal relationship was a necessary 
element of the jury convicting him, see DE 77 at 12. For that reason, and because the facts 
presented at trial overwhelmingly supported the jury’s verdict, the Court should overrule this 
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objection.  
 
“Objection 2: Prosecutorial Language in Fraud Descriptions.” The defense claims that the 
Defendant’s having engaged in a scheme and having unjustly enriched himself is “beyond the 
jury’s verdict,” Obj. at 1-2, but the jury convicted the Defendant of precisely that. That the 
Defendant engaged in a scheme isn’t just in the indictment; it’s in the jury instructions too as a 
necessary element (Element 1) of the wire fraud charges. See DE 77 at 15. And that the Defendant 
unjustly enriched himself was apparent from the trial evidence, which showed the Defendant to 
have pocketed the money and to have spent it on things like a golf club membership while writing 
checks to cash to himself.   
 
“Objection 3: Language Suggesting Intent Beyond the Verdict.” The Government does not 
oppose the PSI including the Defendant’s proposed addition that he was “convicted of submitting 
PPP loan applications containing material misstatements” but does oppose the defense’s request 
that the PSI eliminate anything about the Defendant profiting. The evidence presented at trial 
showed that the Defendant secured the PPP loans at issue and spent them on, among other things, 
a golf club membership, and the jury found the Defendant guilty of having secured those funds 
fraudulently. This evidence presented at trial is sufficient for this Court to retain the PSI’s language 
on this front that the Defendant here opposes.   
 
“Objection 4: Obstruction of Justice Language Based on Alleged Perjury.” The defense 
opposes the two-level enhancement applied for perjury by reasoning that “Mr. McCabe was never 
charged with perjury, and the Court has made no formal finding that he willfully provided false 
testimony.” Obj. at 2. These two bases for objection are improper because a defendant does not 
need to be charged with perjury for the obstruction enhancement to apply and because this Court 
has not had the opportunity to make a finding about his having perjured himself—something it can 
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and should do at sentencing. And while the Defendant does not appear to contest the fact that he 
did indeed lie repeatedly on the stand, see Obj. at 2, this Court will find itself to have many bases 
to make just that finding based on the Defendant’s many lies during his full day of testimony—a 
series of lies discussed further in Section III.B. below.   
 
“Objection 5: Inclusion of Funeral Expenses and Emotional Losses.” The defense claims 
that 18 U.S.C. § 1115 “is not a qualifying offense under the Mandatory Victim Restitution Act,” 
and that “[r]estitution for emotional suffering, funeral costs, or death-related losses is not legally 
permissible unless expressly authorized by statute.” He is wrong in three respects. First, the 
defense confuses mandatory restitution with permissible restitution. He cites to 18 U.S.C. § 3663A 
to support the notion that restitution is not owed here,1 but in fact 18 U.S.C. § 3663 applies to any 
“a defendant convicted of an offense under this title” (i.e., Title 18) and authorizes this Court to 
“order, in addition to … any other penalty authorized by law, that the defendant make restitution 
to any victim of such offense, or if the victim is deceased, to the victim’s estate.” The same statute 
further provides that where a crime “results in the death of a victim,” this Court may order the 
Defendant to “pay an amount equal to the cost of necessary funeral and related services,” though 
the Government agrees that emotional damages are not permissible. See, e.g., United States v.  
Estate of Parsons, 367 F.3d 409, 422 (5th Cir. 2004) (en banc) (Dennis, J., concurring in part) 
("[T]he court cannot order restitution for compensatory damages related to pain, suffering, mental 
or emotional distress or for punitive damages."). 
 
1 The Government agrees that seaman’s manslaughter does not fall within Section 3663A’s 
strictures because involuntary manslaughter is not a “crime of violence” as defined. See United 
States v. Benally, 19 F.4th 1250, 1258 (10th Cir. 2021) (“[I]t is beyond dispute that the district 
court erred in ordering Benally to pay restitution under the MVRA. Benally's offense of 
conviction—involuntary manslaughter in Indian Country—is not a "crime of violence" and does 
not otherwise fall within the scope of the MVRA.”). 
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“Objection 6: Inclusion of Non-Adjudicated Employment Complaints.” The Government 
does not oppose the PSI including the Defendant’s response provided in his Objections to prior 
employment complaints against him, but the Government submits that the language should be 
included in the PSI as relevant to the Defendant’s history and characteristics. The defense does not 
appear to contest the factual claim that these complaints occurred but rather the weight they are 
given; in this respect, and the defense is free to argue that at sentencing. But for PSI purposes, the 
Government submits that these facts should be included because they are relevant to his history. 
 
“Objection 7: Language Suggesting Evasion or Dishonesty.” The Defendant now claims 
that his walking away from a law enforcement conversation never happened and that he never 
“misrepresented the purpose of his boat,” Obj. at 3, but these claims are belied by the trial 
testimony and the jury’s verdict on Count 2. That the Defendant lied about the purpose of his 
vessel to the United States Coast Guard is apparent from the jury convicting him of making a false 
statement about precisely that fact, and that he walked away from law enforcement initially was 
testified to by Sandra Brammeier and David Fowler. That said, it is true that the Defendant 
ultimately gave a post-Miranda statement, which was discussed at trial while impeaching the 
Defendant. 
 
“Objection 8: Use of Guidelines Language Absent Enhancement.” The defense curiously 
claims that “the Probation Office did not formally apply enhancements under U.S.S.G. §§ 3B1.3 
(abuse of trust) or 3B1.1 (aggravating role),” but that is not so.  Rather, Paragraph 45 applies a 
two-level enhancement under Section 3B1.3, which reflects the position of trust that the Defendant 
occupied in captaining the ship. See PSI at 15. For that reason, this Court should deny this objection 
as being based on a misreading of the PSI before it. 
 
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“Objection 9: Mischaracterization of Recreational Vessel Classification.” The defense 
objects to the PSI’s reference to his lying about the purpose of the M/V SOUTHERN COMFORT 
to the USCG, Obj. at 4, but that is precisely what the Defendant was convicted of having done as 
to Count 2. Because the Government’s evidence on this front, which included several witnesses 
testifying that the Defendant discussed the commercial purpose of the M/V SOUTHERN 
COMFORT well before he bought it and then lied on the paperwork by claiming it to be for 
recreational use, this Court should deny this objection based on the facts at trial.  
 
“Objection 10: Misleading Narrative Regarding PPP Forgiveness Documentation.” The 
defense objects to the PSI referring to his PPP loan being fraudulent based on faulty 
documentation, but this Court should deny that objection because the Defendant included false tax 
returns with his applications. The Government introduced evidence that the Defendant provided a 
false Schedule C for his 2020 loan application and a falsified corporate income tax return for his 
2021 one, with the evidence of those documents being falsified consisting of an Internal Revenue 
Service employee testifying that the Defendant never filed the documents and the Defendant’s ex-
wife and former business partner, who testified that she’d never seen the documents and that they 
never made anything close to the income that the documents claimed. For these reasons, this Court 
should overrule this objection as well.  
2. Supplemental Objections 
 
The following responds to the “addendum” objections set forth at Docket Entry 116: 
 
Addendum Objection 1: “Mental Health History and Bureau of Prisons Medical 
Designation.” The Government does not object to the addition of these facts regarding the 
Defendant’s psychiatric history. 
 
Addendum Objection 2: “Request to Bypass FCI Miami Intake.” The Government defers 
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to the Court as to the Defendant’s designation request and does not object to the inclusion of this 
request in the PSI. 
 
Addendum Objection 3: “Pretrial Monitoring and Holiday Restrictions.” The Government 
opposes the Defendant’s request that his time on pretrial monitoring and so-called “holiday 
restrictions” be counted as time in custody. The defense itself admits that this time is “not custodial 
time in the legal sense,” Addendum at 2, and neither of the cases he cites supports his request that 
his time on bond be credited toward his incarceration or be a basis for a downward departure. The 
defense’s case United States v. Mateo, 299 F. Supp. 2d 201, 211-12 (S.D.N.Y. 2004), involved 
downward departure for a woman who was raped and otherwise abused during her pretrial 
confinement, which the court there held to be a basis for a downward departure to her ultimate 
sentence. The defense’s United States v. Peters, 2020 WL 2092617 (D. Conn. May 1, 2020),2 is 
similarly inapposite, involving a compassionate release relating to COVID-19. This case is far 
afield from those, where the Defendant has been on typical pretrial release up to the day the jury 
convicted him. Because the defense’s request is untethered to law or basic common sense, this 
Court should deny this request.  
 
Addendum Objection 4: “Restitution Context – Civil Settlement Paid.” The Government 
does not object to the inclusion of the civil settlement in this case being included in the relevant 
sentencing facts but does contest whether they should receive any weight. The defense cites United 
States v. Kim, 364 F.3d 1235, 1245 (11th Cir. 2004), but there the defendants made payments 
themselves in an extraordinary fashion, paying back 140 percent of the amount they’d benefitted 
while, for example, “dipp[ing] significantly into their life savings and voluntarily undert[aking] an 
enormous amount of debt” to pay their restitution. This case is nothing like that, with an insurance 
 
2 Though the Addendum lists this as a District of Nebraska case, it is a District of Connecticut one. 
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company paying out on a policy it was obligated to at least litigate and the Defendant himself not 
paying a dime. In this respect, while the Government does not oppose including these facts, they 
deserve zero weight from this Court in determining an appropriate sentence.  
 
Addendum Objection 5: “Abrupt Remand and Loss of Closure.” The Government does not 
oppose the PSI including the Defendant’s narrative about being taken into custody. That said, the 
Government would note that the Defendant’s surprise at being remanded is itself surprising 
considering the governing statute, 18 U.S.C. § 3143, expressly contemplates detention for 
defendants who are awaiting sentencing absent a finding by clear and convincing evidence that the 
defendant is not a risk of flight or danger to the community. In that respect, the Government 
submits that the Defendant’s concerns regarding his having been detained should be given zero 
weight in determining an appropriate sentence. 
 
Addendum Objection 6: “Family History and Psychological Background.” The 
Government does not object to the inclusion of the Defendant’s proposed additional family history. 
 
Addendum Objection 7: “Status of Defendant’s Therapy Dog.” The Government does not 
object to the inclusion of the Defendant’s proposed additional personal history. 
 
Addendum Objection 8: “Clarification of Alcohol Use History.” The Government does not 
object to the inclusion of the Defendant’s proposed additional personal history. 
 
Addendum Objection 9: “Civil Settlement Already Paid to Victim’s Family.” The 
Government does not oppose the Defendant including facts relating to a civil settlement by an 
insurance company but does oppose his attempt to offset his restitution against the civil settlement. 
The Government takes this position because the Defendant’s point about a general settlement does 
not meet his burden of showing that the settlement pertained to the specific expenses covered here, 
such as funeral expenses. This position echoes the Sixth Circuit’s analysis in United States v. 
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Sizemore, 850 F.3d 821, 828-29 (6th Cir. 2017), which involved nearly identical facts to those 
here—a manslaughter followed by an insurance payment. Moreover, even were there to be a 
restitution offset here as the victims, that offset would be counterbalanced by the Defendant’s 
restitution owed to the third party who paid off his claim, the insurance company. See, e.g., United 
States v. Bright, 353 F.3d 1114, 1122 (9th Cir. 2004) (third-party payor “would step in the victims’ 
shoes as a subrogee of their restitution claims against” the defendant pursuant to 18 U.S.C.                  
§ 3664(j)(1)). For these reasons, the Government opposes any restitution adjustment as to the 
Defendant under the facts he presents.  
 
Addendum Objection 10: “Factors Warranting Downward Departure or Variance.” The 
Government opposes a downward variance for the same reason it requests a top-of-the-Guidelines 
sentence in Section B below. 
B. A Top-of-the-Guidelines Sentence Here Properly Reflects the Defendant’s Degree of 
Negligence and His Many Brazen Lies While Testifying at Trial. 
 
 
Through this Response, the Government also respectfully submits that a top-of-the-
Guidelines sentence of 78 months in prison is the appropriate sentence to reflect the sentencing 
factors set forth in Section 3553(a)—namely, “the nature and circumstances of the offense,” “the 
seriousness of the offense, to promote respect for the law, and to provide just punishment for the 
offense,” as well as to “afford adequate deterrence to criminal conduct.” 18 U.S.C. § 3553(a)(1) 
& (2)(A)-(B). Specifically, the following three aspects of the Defendant’s conduct warrant a 
sentence that goes beyond the top of the Guidelines range here, making a sentence of 78 months 
wholly appropriate: 
 
First, the Guidelines do not fully account for the degree of recklessness the Defendant’s 
conduct here, which easily surpassed even gross negligence when only simple negligence was 
required. The Defendant operated a scuba charter business and had been doing so for many years, 
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and every fact witness who testified at this trial attested to the known danger that propellers present 
to scuba passengers. Indeed, passengers by the very nature of scuba diving go near the spinning 
blades to enter and exit the vessel, so scuba divers and captains are hyperaware of the danger that 
propeller malfunctions can present. That extreme danger is echoed in the USCG’s marine casualty 
requirements, which require for any captain, not just scuba, that they report losses of propulsion. 
Yet the Defendant simply didn’t care; as shown at trial, he knew full well that his propeller had a 
serious malfunction, and he chose to bring out a group the following day and expose them to that 
danger without so much as a passing warning. This conduct rises beyond the negligence standard 
that the Guidelines contemplates and weighs in favor of a sentence at the top of his Guidelines.  
 
Second, while the Guidelines provide a two-point enhancement for his obstructing justice, 
that two level enhancement fails to fully account for the dizzying scope of the Defendant’s lies. 
Over an entire day of trial testimony, the Defendant lied about virtually every aspect of this case 
in the face of overwhelming evidence. He lied about the vessel running aground when five separate 
witnesses testified it had. He lied about the fake income tax forms he submitted being part of the 
PPP loan application packages when the bank representatives had just finished testifying about 
precisely that fact. He lied about what killed M.C.G.F., drawing on an easel in a desperate attempt 
to convince the jury that the coastal current somehow caused the deep chop wounds that she’d 
sustained. He lied about the M/V SOUTHERN COMFORT’s registration and his filing his PPP 
loans by claiming that he called the respective people and that they’d told him to do it. He lied 
about knowing there was an engine problem, which led the Government to impeach him with a 
prior statement where he acknowledged there was one. By the end, his lies covered every count 
and the testimony from virtually every witness the Government presented, and the jury rightly 
rejected his claims by convicting him. The Government respectfully submits that the scope of these 
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lies go far beyond what the Section 3B1.1 obstruction enhancement contemplates, in that the 
Defendant’s testimony was so replete with lies that it went beyond obstructing justice to making a 
mockery of the entire proceeding. For those reasons, the Defendant’s testimony is a second basis 
for this Court to sentence the Defendant to a top-of-Guidelines sentence. 
 
Third, the Defendant’s other crimes are not factored into the Guidelines but demonstrate a 
disregard for the law that compels them to be accounted for. The Defendant’s response to 
committing the crime of involuntary manslaughter was to move to intentional, willful fraud. While 
the Guidelines’ multi-count provisions have a system of accounting for other crimes, they do not 
always account for situations like this one where one crime leads to another. To promote respect 
for the law, the Government respectfully submits that even if these other crimes did not move the 
Guidelines range, they are nevertheless a compelling reason for this Court to sentence the 
Defendant to the top of the Guidelines range.  
IV. 
CONCLUSION 
For the foregoing reasons, the Court should sentence the Defendant to 78 months in prison 
for the crimes at issue in this tragic case.  
 
 
 
 
 
 
Respectfully submitted, 
 
    
 
 
 
 
 
HAYDEN P. O’BYRNE 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
Date: May 30, 2025  
 
      By:   /s/ Zachary A. Keller  
 
 
 
ZACHARY A. KELLER 
Assistant United States Attorney 
US Attorney’s Office – SDFL 
Court No: A5502767 
99 NE 4th Street, 6th Floor 
Miami, Florida 33132 
Tel: (305) 961-9023 
 
 
 
 
 
 
Email: zachary.keller@usdoj.gov 
 
 
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CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on May 30, 2025, I electronically filed the foregoing document 
with the Clerk of the Court using CM/ECF.  
 
/s/ Zachary A. Keller  
ZACHARY A. KELLER 
Assistant United States Attorney 
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