Sentencing Memorandum by USA as to Joel Wright — USA v. Sanders et al. (Dkt. 204)

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The Government's Sentencing Memorandum for Joel Wright, Case No. 24-00029-02-CR-W-BP, in the U.S. District Court for the Western District of Missouri, filed 01/10/25 as Document 204 in 4:24-cr-00029-BP. It recommends probation with a condition of 4 months' home detention, against a PSR range of 4 to 10 months and restitution of $51,665. It states that Wright pled guilty on August 22, 2024 to conspiracy to commit wire fraud under 18 U.S.C. § 1349, as part of a group organized by Daisha Sanders, and received a $20,832.50 PPP loan on an application claiming a sole proprietorship with a monthly payroll of $8,333 that did not exist. It also states that codefendants Jeffrey Chillis and Jordan Nichols each transferred $5,000 to Wright after receiving PPP loans. It is signed /s/ Paul S. Becker, Assistant United States Attorney.

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IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
 
Plaintiff, 
 
 
v. 
 
JOEL WRIGHT, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  24-00029-02-CR-W-BP 
 
GOVERNMENT’S SENTENCING MEMORANDUM 
 
The United States of America, by and through its undersigned counsel, files its 
sentencing memorandum in this case. The government recommends a sentence of probation with 
a condition of 4 months’ home detention. The presentence report calculated the sentencing range 
from 4 to 10 months and restitution of $51,665. (PSR¶¶ 65 & 77-80.) 
PROCEDURAL AND FACTUAL BACKGROUND 
On August 22, 2024, Defendant  Joel Wright  pled guilty to Count One of the indictment, 
conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349. (PSR ¶ 1.) The 
maximum possible penalty for conspiracy to commit wire fraud is 20 years’ imprisonment. The 
defendant’s offense conduct is outlined in paragraphs 4 - 9, 11 – 12, 17, and 21 of the PSR. 
The defendant was part of a group of individuals organized by his wife Daisha Sanders to 
submit fraudulent Paycheck Protection Program (PPP) loans. Mr. Wright, aided by 
Ms. Daisha Sanders, submitted an application which claimed he was the sole proprietor of 
a business that had a monthly payroll of $8,333. The defendant also submitted a 2019 tax return 
that stated the business had gross revenues of $144,080 and net income of $99,982 in 2019. In fact, 
Case 4:24-cr-00029-BP     Document 204     Filed 01/10/25     Page 1 of 4

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the defendant did not have such a business, and it did not have any revenues in the year prior to the 
pandemic. The defendant received a $20,832.50 PPP loan. 
The evidence also indicates that Joel Wright assisted two other codefendants in obtaining 
fraudulent PPP loans. On April 8, 2021, Jeffrey Chillis received a PPP loan in the amount of 
$20,833. A review of Chillis’ bank records found that on April 13, 2021, he transferred $5,000 to 
Joel Wright via CashApp. On May 11, 2021, Jordan Nichols received a $20,832 PPP loan. A 
review of Nichols bank records indicate that on May 16, 2021, he transferred $5000 to Joel Wright 
via Paypal. 
DISCUSSION 
I. 
Sentencing Analysis 
There are no outstanding objections to the presentence report and, therefore, the offense 
level would be 9, Criminal History Category I, resulting in a guideline range of 4 to 10 months. As 
this Court is aware, 18 U.S.C. § 3553(a) sets forth the factors to be considered in determining an 
appropriate sentence. In evaluating the appropriate sentence for this defendant, the United 
States notes the following: 
Nature of the offense: 
The defendant falsely applied for and received a $20,832 pandemic relief loan. These funds 
were intended to assist businesses that were impacted by the pandemic. While this amount is small 
compared to other pandemic relief fraud, the defendant should have been aware that this scheme 
was unlawful. It also appears from the evidence that the defendant was involved in 
receiving money from codefendants who also received fraudulent PPP loans. 
The history and characteristics of the defendant: 
The defendant has no criminal history points and is employed as a property manager. 
Case 4:24-cr-00029-BP     Document 204     Filed 01/10/25     Page 2 of 4

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Seriousness of the Offense, Deterrence, Protection, and Rehabilitation: 
This was a serious offense and there is a need to deter the defendant and others from 
fraudulently taking advantage of emergency relief funds. 
Sentencing: 
As noted by the Court in United States v. Anderson, 664 F.3d 758, 764-765 (8th Cir. 2012), 
the analysis for reviewing the reasonableness of a sentence is well-settled: 
We review substantive reasonableness for an abuse of discretion, “‘tak[ing] 
into account the totality of the circumstances, including the extent of any 
variance from the Guidelines range.’” United States v. Feemster, 572 F.3d 
455, 461 (8th Cir. 2009) (en banc) (quoting Gall v. United States, 552 U.S. 
38, 51, 128 S. Ct. 586, 169 L.Ed.2d 445 (2007)). If a sentence is outside of 
the Guidelines range, “we ‘may consider the extent of the deviation, but 
must give due deference to the district court’s decision that the § 3553(a) 
factors, on a whole, justify the extent of the variance.’” Id. at 461–62 
(quoting Gall, 552 U.S. at 51, 128 S. Ct. 586) “Just because we ‘might 
reasonably have concluded that a different sentence was appropriate is 
insufficient to justify reversal of the district court.’” Id. at 462 
(quoting Gall, 552 U.S. at 51, 128 S. Ct. 586). “‘[I]t will be the unusual 
case when we reverse a district court sentence ... as substantively 
unreasonable.’” Id at 464 (quoting United States v. Gardellini, 545 F.3d 
1089, 1090 (D.C. Cir. 2008)). 
 
As noted by Judge Colloton in his concurrence in United States v. Burman, 666 F.3d 
1113, 1120 (8th Cir. 2012) citing, Gall v. United States, 552 U.S. 38, 50-51, 128 S. Ct. 586 
(2007), the “proper measure of reasonableness under § 3553(a) is not whether the variance from 
an advisory guideline range is reasonable, but whether the ultimate sentence is reasonable in light 
of the § 3553(a) factors taken as a whole.” 
The issue presented to the Court then is what sentence is reasonable given the need to deter 
others who would engage in such illegal misappropriation of government emergency monies.  
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A sentence of probation with a condition of home detention would deter the defendant and 
send a message to others that such fraud schemes are unlawful and will be dealt with seriously by 
the United States District Court. 
Respectfully submitted, 
 
 
 
 
 
 
 
 
Teresa A. Moore 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
By: 
/s/ Paul S. Becker 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
Charles Evans Whittaker Courthouse 
 
400 E. 9th Street, Suite 5510 
 
Kansas City, Missouri 64106 
 
CERTIFICATE OF SERVICE 
 
The undersigned hereby certifies that a copy of the foregoing was delivered on January 10, 
2025, to the Electronic Case Filing (CM-ECF) system of the United States District Court for the 
Western District of Missouri for electronic delivery to all counsel of record. 
 
 
 
 
 
 
 
 
/s/ Paul S. Becker 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
Case 4:24-cr-00029-BP     Document 204     Filed 01/10/25     Page 4 of 4

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