Complaint — United States v. Lakeshia Bias (Eastern District of Louisiana)

Summary

A civil complaint filed April 24, 2025, by the United States against Lakeshia Bias in the U.S. District Court for the Eastern District of Louisiana, Case 2:25-cv-00799-JCZ-DPC. It alleges that Bias received a PPP loan of $20,832.00 on or about March 18, 2021, through Capital Plus Financial, LLC, based on false statements including a claimed $101,305.00 in gross income from a hair salon, and that the SBA forgave the loan. The complaint pleads unjust enrichment, payment by mistake, a civil penalty under FIRREA, and treble damages and a civil penalty under the False Claims Act. It asks for treble damages of $70,298.07 or, alternatively, single damages of $23,432.69, plus civil penalties. Assistant United States Attorney Loan "Mimi" Nguyen signs /s/ for the government.

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“Complaint — United States v. Lakeshia Bias (Eastern District of Louisiana).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-complaint-16d2044c5c/, SHA-256 f24cc10a159230cb1ac2b12f93a81e0435ac9f4977b4f92e67f7ec0abd36ab04.

Full text

Case 2:25-cv-00799-JCZ-DPC Document 1 Filed 04/24/25 Page 1 of 9

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

UNITED STATES OF AMERICA * CIVIL ACTION

v. * NO.

LAKESHIA BIAS * JUDGE

* MAG.

COMPLAINT

NOW INTO COURT, through the undersigned Assistant United States Attorney, comes

plaintiff, the United States of America, and respectfully submits its complaint against defendant,

Lakeshia Bias, and hereby alleges the following.

Parties, Jurisdiction, and Venue

Plaintiff is the United States of America proceeding in its sovereign capacity.

Defendant is Lakeshia Bias, a Louisiana resident domiciled at 209 Marietta Pl., Gray, Louisiana

70359.

Jurisdiction is proper under 28 U.S.C. §§ 1331 and 1345.

Venue is proper under 28 U.S.C. § 1391(b) since Bias is domiciled in the Eastern District

of Louisiana.

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Facts

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was a federal law

enacted in or around March 2020 and designed to provide emergency financial assistance to the

millions of Americans suffering the economic effects caused by the COVID-19 pandemic. One

source of relief provided by the CARES Act was the authorization of forgivable loans to small

businesses for job retention and certain other expenses, through a program referred to as the

Paycheck Protection Program (PPP).

A PPP loan application was processed by a participating lender. If a PPP loan application

was approved, the participating lender funded the PPP loan using its own money. While it was the

participating lender that issued the PPP loan, the loan was 100% guaranteed by the United States

Small Business Administration (SBA). Data from the application, including information about the

borrower, the total amount of the loan, and the listed number of employees, was transmitted by the

lender to the SBA in the course of processing the loan and subsequent forgiveness process.

The application process to obtain a PPP loan required the eligible recipient to make the

following good-faith certifications and acknowledgments, among others:

a. That the applicant was eligible to receive a PPP loan under the rules in effect at

the time the application was submitted;

b. That the uncertainty of current economic conditions made the loan request

necessary to support the ongoing operations of the eligible recipient;

c. That the applicant was in operation on January 10, 2018, had not permanently

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closed, and was either an eligible self-employed individual, independent

contractor, or sole proprietorship with no employees, or had employees for

whom it paid salaries and payroll taxes or paid independent contractors, as

reported on Form(s) 1099-MISC;

d. That the funds would be used to retain workers and maintain payroll; or make

payments for mortgage interest, rent, utilities, or other covered costs under the

PPP Rules;

e. That if the funds were knowingly used for unauthorized purposes, the federal

government may find the individual legally liable for such charges as fraud;

f. That the information provided in the application and all supporting documents

and forms was true and accurate in all material respects;

g. That the applicant understood that knowingly making a false statement to obtain

a guaranteed loan from SBA is punishable under the law, including under 18

U.S.C. §§ 1001 and 3571 by imprisonment of not more than five years and/or

a fine of up to $250,000.00; under 15 U.S.C. § 645 by imprisonment of not

more than two years and/or a fine of not more than $5,000.00; and, if submitted

to a federally insured institution, under 18 U.S.C. § 1014 by imprisonment of

not more than 30 years and/or a fine of not more than $1,000,000.00; and

h. That the lender would confirm the eligible loan amount using the documents

submitted by the applicant.

On or about March 18, 2021, Bias received a PPP loan in the amount of $20,832.00 based

upon false and fraudulent records and statements in a claim for payment submitted to Capital Plus

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Financial, LLC. In the PPP loan application, Bias, or persons acting in conspiracy with her,

misrepresented her annual income and payroll costs, which were used in calculating her eligible

loan amount.

Further, Bias knowingly used the PPP loan funds for unauthorized purposes.

10.

Bias knowingly misrepresented her use of the funds on the forgiveness application

submitted for the PPP loans. Based upon these false representations, the SBA forgave Bias’s PPP

loan of $20,832.00 and accrued interest of $100.69. The SBA also paid $2,500 in processing fees

to Capital Plus Financial, LLC for the PPP loan disbursed to Bias.

Causes of Action

Count I - Unjust Enrichment

11.

By obtaining from the United States funds to which she was not entitled, Bias was unjustly

enriched and the United States is entitled to damages in the total amount of $23,432.69, plus post-

judgment interest accruing on that amount.

Count II - Payment by Mistake

12.

The United States, acting in reasonable reliance on the truthfulness of the statements

contained in Bias’s PPP loan application, approved a PPP loan to which Bias was not entitled.

13.

The United States, acting in reasonable reliance on the truthfulness of the statements

contained in Bias’s PPP loan-forgiveness application, forgave her PPP loan when it was not

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eligible for forgiveness.

14.

Thus, the United States is entitled to recoup the amount of Bias’s PPP loan in the total

amount of $23,432.69 plus post-judgment interest accruing on that amount.

Count III – Civil Penalty under FIRREA

15.

Section 951 of the Financial Institutions Reform, Recovery, and Enforcement Act

(FIRREA), codified at 12 U.S.C. § 1833a, provides that the Attorney General may recover civil

penalties of up to $1 million per violation (adjusted to $2,048,915) against persons who commit

specified violations as established by a preponderance of the evidence.

16.

The predicate violations identified in Section 951 that can form the basis for liability under

FIRREA include, among others: (a) knowingly or willfully making a materially false or fraudulent

statement affecting a federally insured financial institution (18 U.S.C. § 1001); (b) making a false

statement on a loan application to a financial institution, “the accounts of which are insured by the

Federal Deposit Insurance Corporation” (18 U.S.C. § 1014); and (c) knowingly making a false

statement for the purpose of influencing a decision by the Administrator of the SBA or to obtain a

loan, money, or anything of value under the SBA’s 7(a) program, including the PPP (15 U.S.C.

§ 645(a)). See 12 U.S.C. § 1833a(c).

17.

Bias unlawfully, willfully, and knowingly made false statements and certifications to SBA

Lenders and the SBA in violation of 15 U.S.C. § 645(a). Specifically, Bias signed the PPP loan

agreements, thereby knowingly and falsely representing that she would “comply with all SBA

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guidance” as it applied to the PPP loans. These statements were knowingly false and made for the

purpose of influencing the SBA in order to obtain PPP loan proceeds in violation of 15 U.S.C.

§ 645(a).

18.

Bias is liable for civil penalties up to the maximum amount authorized under 12 U.S.C. §

1833a(b).

Count IV – Treble Damages and Civil Penalty under the False Claims Act

19.

The False Claims Act (FCA) provides, in pertinent part, that any person who: “knowingly

presents, or causes to be presented, a false or fraudulent claim for payment or approval;” or

“knowingly makes, uses, or causes to be made or used, a false record or statement material to a

false or fraudulent claim” is liable to the United States for three times the amount of damages

which the United States sustains, plus a civil penalty per violation. 31 U.S.C. § 3729(a)(1)(A)–

(B).

20.

Bias knowingly caused a false or fraudulent claim for payment to be presented to the SBA,

and knowingly caused a false record or statement material to a false or fraudulent claim to be used,

all in violation of the FCA, in the following specific ways.

a. On or around March 14, 2021, Bias, or persons acting in conspiracy with

her, falsely claimed in an application for a PPP loan that Bias was the sole proprietor of a

hair salon that was in operation in 2018, when in fact Bias was not an eligible self-

employed individual or an employer in that line of business.

b. On or around March 14, 2021, Bias, or persons acting in conspiracy with

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her, falsely claimed that she had earned $101,305.00 in gross income from the hair salon

as reported on IRS Form 1040, Schedule C, Line 7, when in fact she did not earn nor report

income in that amount.

c. On or around March 14, 2021, Bias, or persons acting in conspiracy with

her, submitted a false and fraudulent Form 1040, Schedule C showing $101,305.00 in gross

income, when in fact she did not earn that amount, nor did she file the Form 1040 with the

IRS.

d. On or around March 14, 2021, Bias, or persons acting in conspiracy with

her, further falsely claimed that the PPP loan funds would be used for authorized

expenditures under PPP rules (such as payroll, mortgage interest, rent, utilities, and covered

supplier costs), when in fact Bias actually used the funds for unauthorized expenditures.

e. On or around March 14, 2021, Bias, or persons acting in conspiracy with

her, certified that the information provided in his application and supporting documentation

was true and correct in all material respects, when in fact it was false and fraudulent in the

above-stated material respects, among others to be shown at trial.

f. On or around September 2, 2021, Bias, or persons acting in conspiracy with

her, applied to have her PPP loan forgiven and falsely claimed that she spent $12,499.80

of the loan proceeds on payroll, when in fact she used the entirety of the PPP loan for other

purposes.

g. On or around September 2, 2021, Bias, or persons acting in conspiracy with

her, falsely certified in her PPP loan forgiveness application that she had complied with all

requirements of the PPP Rules and guidance related to eligible uses of PPP loan proceeds,

when in fact she had not complied, but rather had spent the PPP loan proceeds on ineligible

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personal uses.

h. On or around September 2, 2021, Bias, or persons acting in conspiracy with

her, falsely certified that the information provided in her PPP loan-forgiveness application

was true and correct in all material respects, when in fact the PPP loan-forgiveness

application had false, material information the SBA relied upon to forgive Bias’s PPP loan.

21.

Because of these false and fraudulent claims, records, and statements, the United States

(acting through the SBA), was financially damaged in the principal amount of the forgiven PPP

loan ($20,832.00), forgiven accrued interest ($100.69), and the processing fees SBA paid to

Capital Plus Financial, LLC ($2,500), in the total amount of $23,432.69.

22.

The United States is further entitled to treble damages on this amount, plus a civil penalty

under the FCA. 31 U.S.C. § 3729(a)(1).

Prayer for Relief

WHEREFORE, the United States prays that its complaint be deemed sufficient and that,

after due proceedings, that there be judgment in its favor and against Bias awarding:

1) Treble damages in the total amount of $70,298.07 under the FCA (Count IV), or,

alternatively, single damages of $23,432.69 for unjust enrichment/payment by

mistake (Counts I and II);

2) A civil penalty of no less than $14,308 under the FCA (Count IV);

3) A civil penalty of no less than $23,432.69 under FIRREA (Count III);

4) Post-judgment interest; and

3) Any further relief the Court deems proper.

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Respectfully submitted,

MICHAEL M. SIMPSON
ACTING UNITED STATES ATTORNEY

/s/ Loan “Mimi” Nguyen
Loan “Mimi” Nguyen
Assistant United States Attorney
U.S. Attorney’s Office (E.D. La.)
650 Poydras Street, Suite 1600
New Orleans, Louisiana 70130-7212
Telephone: (504) 680-3076
Email: Mimi.Nguyen @usdoj.gov

United States will send request for waiver of service to:
Lakeshia Bias
209 Marietta Pl.
Gray, Louisiana 70359

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File and source

File: 1-complaint.pdf
Size: 299,195 bytes
SHA-256: f24cc10a159230cb1ac2b12f93a81e0435ac9f4977b4f92e67f7ec0abd36ab04
Our copy: 1-complaint.pdf
Original: No public link identified.