Memorandum and Order on Defendant's Motion for Release — United States v. Jean-Jacques

Record facts

U.S. District Court for the District of Massachusetts · No. 1:26-cr-10030-RGS · Doc. 63 · 2026-04-20 · Docket on CourtListener

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A memorandum and order by U.S. District Judge Richard G. Stearns dated April 20, 2026 in United States of America v. Sniders Jean-Jacques, Criminal Action Nos. 26-10030 and 26-10031-RGS, in the U.S. District Court for the District of Massachusetts, filed as Doc. 63 in No. 1:26-cr-10030-RGS. It rules on the defendant's motion for immediate release and the government's appeal of a Magistrate Judge's release order entered after a February 16, 2026 detention hearing in the Southern District of Florida. Reviewing de novo under 18 U.S.C. § 3142(g), the court cites a prior conviction for similar crimes, a government loss estimate exceeding $13 million and a guideline range of 188 to 235 months as incentives to flee. The court denies release, reverses the release order and orders the defendant detained pending trial.

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
 
CRIMINAL ACTION NOS. 26-10030 and 26-10031-RGS 
 
 
UNITED STATES OF AMERICA 
 
v. 
 
SNIDERS JEAN-JACQUES 
 
 
MEMORANDUM AND ORDER ON DEFENDANT’S  
MOTION FOR IMMEDIATE RELEASE 
AND THE GOVERNMENT’S APPEAL OF THE MAGISTATE JUDGE’S  
ORDER OF RELEASE 
 
 
April 20, 2026 
 
STEARNS, D.J.  
Defendant Sniders Jean-Jacques has been indicted in the District of 
Massachusetts for bank and wire fraud conspiracy and, in a separate 
indictment, for wire fraud conspiracy involving the alleged theft of funds 
from the Covid-era Paycheck Protection Program.  Shortly after the 
indictments were handed up, on February 9, 2026, Jean-Jacques was 
arrested in Florida where he resides. After a detention hearing in the 
Southern District of Florida, held on February 16, 2026, the Magistrate 
Judge ordered defendant released on conditions but stayed the order 
through February 18, 2026.  On February 17, 2026, the government filed an 
emergency motion seeking a further stay, which this court allowed pending 
Case 1:26-cr-10030-RGS     Document 63     Filed 04/20/26     Page 1 of 4

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defendant’s appearance in the District of Massachusetts.  Defendant 
appeals the stay of the release order, while the government seeks revocation 
of the release order.  The court held a hearing on the appeal on April 7, 
2026.  In addition to the parties’ arguments and briefings, the court has had 
the benefit of the Pretrial Services Report prepared in the Southern District 
of Florida and the transcript of the hearing before Magistrate Judge Marty 
Fulgueria Elfenbein.  For the reasons stated below, the court will allow the 
government’s motion to reverse the Magistrate Judge’s release order and 
further order that the defendant be detained pending trial. 
Review of an order of detention or release by the district court is de 
novo.  United States v. Tortora, 922 F.2d 880, 883 n.4 (1st Cir. 1990).  
While the standard of review precludes deference to the Magistrate Judge’s 
decision, comity requires that it be given consideration with respect. In 
making its independent determination, the court is directed by 18 U.S.C. § 
3142(g) and the case law to weigh the nature and circumstances of the 
offense, the weight of the evidence, the history and characteristics of the 
defendant, and any risk of flight or danger that might be posed to any person 
or the community by defendant’s release. Risk of flight is decided by a 
preponderance of the evidence, danger to the community by the stricter 
standard of clear and convincing evidence. 
Case 1:26-cr-10030-RGS     Document 63     Filed 04/20/26     Page 2 of 4

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With respect to the first three considerations, while wire fraud and 
conspiracy are not per se crimes of violence, defendant’s situation is 
complicated by the fact that he has been previously convicted of virtually the 
same crimes (for which he served a two-year federal sentence) when the 
present crimes were allegedly hatched.  That reality and the scale of his 
alleged crimes, which resulted in a loss that, by the government’s estimate, 
exceeds $13 million dollars, will expose him if convicted to a guideline 
sentencing range of 188 to 235 months.  That prospect alone provides a 
powerful incentive to flee.   
The defendant’s history of appropriating the identities of others (an 
integral facet of his criminal activity) and his deep roots in Haiti further 
enhance the likelihood of flight.  While Jean-Jacques is a U.S. citizen, as the 
government points out, his roots in the Florida community in which he 
resides are weak. He is not married, and while he has children, he is 
estranged from them and their current custodial mother (who is suing him 
for child support).  He does not own a home and, by all appearances, has no 
permanent address.  For all these reasons, I conclude that there are no 
combination of conditions of release that will ensure defendant’s presence 
Case 1:26-cr-10030-RGS     Document 63     Filed 04/20/26     Page 3 of 4

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for trial.1   
For the foregoing reasons, defendant’s motion for immediate release is 
DENIED.  The order of release entered by the Magistrate Judge is reversed 
and the defendant ordered detained pending trial.  
 
SO ORDERED. 
 
/s/ Richard G. Stearns 
 
 
 
 
 
 
UNITED STATES DISTRICT JUDGE 
 
 
 
 
 
 
 
 
 
 
1 While the government argues (with support in cases from other 
circuits), that economic as well as violent crimes can be weighed in a danger 
to the safety of the community analysis, see United States v. Cook, 880 F.2d 
1158, 1161 (10th Cir. 1989), I need not consider this ground for detention 
given the strength of the case for a likelihood of flight.  I have considered 
the allegations that defendant has made threats against others in the past, 
including potential witnesses, and has been reported at times to be in 
possession of a firearm, in considering his character. While these may not be 
evidence per se of a proclivity to flee, they do tend to corroborate the 
government’s contention that the defendant’s regard for the law, including 
the likelihood of his abiding by conditions of release, is questionable. 
Case 1:26-cr-10030-RGS     Document 63     Filed 04/20/26     Page 4 of 4

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