Sentencing Memorandum by USA as to Alfred Hayes, IV — USA v. Sanders et al. (Dkt. 254)

Record facts

U.S. District Court records for the Western District of Missouri and Western District of Washington · No. 4:24-cr-00029-BP · Doc. 254 · 2025-03-27 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
 
Plaintiff, 
 
 
v. 
 
ALFRED HAYES IV, 
 
 
 
 
 
Defendant. 
 
 
 
 
Case No.  24-00029-09-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 three years’ probation. The 
presentence report calculated the sentencing range from zero to six months and restitution of 
$20,832. (PSR¶¶ 66 & 78.) 
PROCEDURAL AND FACTUAL BACKGROUND 
On December 17, 2024, Defendant Alfred Hayes IV 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, and 19 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. Hayes, 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 April 8, 2021, the defendant 
received a $20,832.50 PPP loan. On April 9, 2021, Mr. Hayes transferred $5,000 to 
Case 4:24-cr-00029-BP     Document 254     Filed 03/27/25     Page 1 of 3

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Daisha Sanders. On October 26, 2021, an application for PPP loan forgiveness was filed with the 
SBA, claiming that $20,832 of the loan was spent on payroll costs. On October 29, 2021, the 
PPP loan was forgiven by the SBA. 
DISCUSSION 
I. 
Sentencing Analysis 
There are no outstanding objections to the presentence report and, therefore, the offense 
level would be 7, Criminal History Category I, resulting in a guideline range of zero to 6 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 no criminal convictions and is employed. (PSR ¶ 56.) 
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. 
 
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A sentence of probation would adequately 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 27, 
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 254     Filed 03/27/25     Page 3 of 3

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