Sentencing Memorandum by USA as to Jordan Nichols — USA v. Sanders et al. (Dkt. 246)

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The Government's Sentencing Memorandum for Jordan Nichols, Case No. 24-00029-11-CR-W-BP, in the U.S. District Court for the Western District of Missouri, filed March 17, 2025 as Document 246. The government recommends probation with a condition of 8 months' home detention, against a presentence range of 8 to 14 months and restitution of $20,832. It states that on October 29, 2024 the defendant pleaded guilty to Count One, conspiracy to commit wire fraud under 18 U.S.C. § 1349, and that an application aided by Daisha Sanders claimed a sole proprietorship with gross revenues of $144,080 in 2019. It states that the defendant received a $20,832.50 PPP loan on May 11, 2021 and transferred $5,000 the same day to Joel Wright, and that the offense level of 9 and Criminal History Category III reflect prior convictions. 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. 
 
JORDAN NICHOLS, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  24-00029-11-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 8 months’ home detention. The presentence report calculated the sentencing range 
from 8 to 14 months and restitution of $20,832. (PSR¶¶ 83 & 95.) 
PROCEDURAL AND FACTUAL BACKGROUND 
On October 29, 2024, Defendant Jordan Nichols 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 5 - 10, and 21 of the PSR. 
The defendant was part of a group of individuals organized by Daisha Sanders to submit 
fraudulent Paycheck Protection Program (PPP) loans. Mr. Nichols, aided by Ms. Sanders, 
submitted an application which claimed he was the sole proprietor of a business that had gross 
revenues of $144,080 and net income of $99,982 in 2019. In fact, the defendant did not have such 
a business, and it did not have any revenue in the year prior to the pandemic. On May 11, 2021, 
Case 4:24-cr-00029-BP     Document 246     Filed 03/17/25     Page 1 of 3

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the defendant received a $20,832.50 PPP loan. On the same date, Mr. Nichols transferred $5,000 
to Joel Wright, Daisha Sanders’ husband. 
DISCUSSION 
I. 
Sentencing Analysis 
There are no outstanding objections to the presentence report and, therefore, the offense 
level would be 9, Criminal History Category III, resulting in a guideline range of 8 to 14 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. 
The history and characteristics of the defendant: 
The defendant has a significant criminal history that is different from the other PPP loan 
defendants. When the defendant was younger, he had misdemeanor and felony convictions 
including fleeing from police officers. In 2021, the defendant has two convictions for driving while 
intoxicated. The defendant also has a pending case where he fled from police and guns were 
recovered from the fleeing car. (PSR ¶ 53.) 
The defendant appears to be employed and is paying child support. (PSR ¶¶ 73 & 64.) 
 
 
Case 4:24-cr-00029-BP     Document 246     Filed 03/17/25     Page 2 of 3

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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. 
The issue presented to the Court is what sentence is reasonable given the need to deter 
others who would engage in such illegal misappropriation of government emergency monies and 
adequately punish the defendant considering his criminal record. 
A sentence of probation with a condition of 8 months’ 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, 
 
 
 
 
 
 
 
 
Jeffrey P. Ray 
 
 
 
 
 
 
 
Acting United States Attorney 
 
 
 
 
 
 
 
By: 
/s/ Paul S. Becker 
 
Paul S. Becker 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
Fraud and Corruption Unit 
 
 
 
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 March 17, 
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 246     Filed 03/17/25     Page 3 of 3

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