Indictment — United States v. Michelle Jackson and Ryachanelle Morris (Middle District of Louisiana)

Summary

An indictment filed 08/12/26 in the Middle District of Louisiana, Case 3:26-cr-00089-JWD-SDJ, charges Michelle W. Jackson, also known as Michelle Walters Jackson, and Ryachanelle L. Morris with conspiracy to commit wire fraud (Count 1), and charges Jackson alone with wire fraud in Counts Two through Four. It alleges that from in or around April 2020 until at least November 2021 the defendants submitted false PPP, EIDL, PUA and UI applications, including UI claims in California, Arizona and Louisiana and PPP applications overstating payroll and employees. The grand jury states that Jackson and Morris gained or tried to gain control of more than $350,000.00 in pandemic benefit funds, spent on shopping and dining out. The wire counts are deposits of $17,385.00, $63,479.00 and $65,564.00 from Financial Lender 1.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors. Page 13 of 13 is not shown because the text could not be recognized reliably.

Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page1of13

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA

INDICTMENT FOR CONSPIRACY TO COMMIT WIRE FRAUD,
WIRE FRAUD, AND NOTICE OF FORFEITURE

UNITED STATES OF AMERICA CRIMINAL NO. 26-89-JWD-SDJ

versus
18 U.S.C. § 1349

18 U.S.C. § 1343

MICHELLE W. JACKSON, a.k.a. : 18 U.S.C. § 981(a)(1)(C)

“Michelle Walters Jackson,” and : 21 U.S.C. § 853(p)

RYACHANELLE L. MORRIS 28 U.S.C. § 2461(c)
THE GRAND JURY CHARGES:

At all times relevant to this Indictment:

1. Defendant, MICHELLE W. JACKSON, a.k.a. “Michelle Walters Jackson,”
was a resident of Baton Rouge, Louisiana, within the Middle District of Louisiana.

2. Defendant, RYACHANELLE L. MORRIS, was a resident of Vacherie,
Louisiana, within the Eastern District of Louisiana.

Be Financial Lender 1 was an online financial technology company based in
Atlanta, Georgia, that engaged in lending to small businesses. Financial Lender 1 participated
in the SBA’s Paycheck Protection Program (“PPP”) as a lender and, as such, was authorized
to lend funds to eligible borrowers under the terms of the PPP.

4, Financial Lender 2 was an online financial technology company based in Jersey
City, New Jersey, that engaged in lending to small businesses and provided online business

banking services. Beginning in Spring of 2021, MORRIS maintained an account there in the

name of Da Hood Rich Collection, ending in 1681.

USA Sealed Group

USPO
USM
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page 2of13

5. Bank 1 was a financial institution domiciled in Baton Rouge, Louisiana.
JACKSON maintained an account there in the name of MNR Total Services, LLC.

6. Bank 2 was a financial institution domiciled in Vienna, Virginia. JACKSON
maintained an account there in her name.

COVID-19 Disaster-Relief Programs

me The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in or around March of 2020 and designed to provide emergency financial
assistance to millions of Americans who were suffering the economic effects of the COVID-
19 pandemic. The CARES Act provided relief to small businesses through the Paycheck
Protection Program (“PPP”) and the expansion of the Economic Injury Disaster Loan
(“EIDL”) Program. Other programs, including the Pandemic Unemployment Assistance
Program (“PUA”), Federal Pandemic Unemployment Compensation (“FPUC”), and the Lost
Wages Assistance Program (“LWAP”), expanded unemployment insurance (“UI”) eligibility
and increased UI benefits.

Paycheck Protection Program

8. The Paycheck Protection Program (“PPP”) was administered by the Small
Business Administration (“SBA”) and provided forgivable loans to small businesses for job
retention and certain other expenses. The PPP permitted participating third-party lenders to
approve and disburse SBA-backed PPP loans to cover payroll, fixed debts, utilities,
rent/mortgage, accounts payable and other bills incurred by qualifying businesses during, and
resulting from, the COVID-19 pandemic. PPP loans were fully guaranteed by the SBA.

9. To obtain a PPP loan, a qualifying business had to submit a PPP loan

application, which was signed by an authorized representative of the business. The PPP loan

2
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page3of13

application required the business (through its authorized representative) to acknowledge the
program rules and make certain affirmative certifications, including that the business was in
operation and either had employees for whom it paid salaries and payroll taxes or paid
independent contractors. A business applying for a PPP loan was required to provide
documentation showing its payroll expenses, such as filed federal income tax documents.

10. | PPP loan applications were electronically submitted or caused to be submitted
by the borrower to a third-party SBA-approved lender, like Financial Lender 1. Once
approved, the business received the PPP loan proceeds via an electronic funds transfer from
the third-party lender to a financial account under the control of the business.

11. The proceeds of a PPP loan were to be used for certain specified items, such as
payroll costs, costs related to the continuation of group health care benefits, or mortgage
interest payments. The proceeds of a PPP loan were not permitted to be used by the borrower
to purchase consumer goods, automobiles, personal residences, clothing, or jewelry, or to fund
the borrower’s ordinary day-to-day living expenses unrelated to the specified authorized
expenses.

Economic Injury Disaster Loan Program

12. The CARES Act expanded an existing disaster-related program, the Economic
Injury Disaster Loan (“EIDL”) program, to provide loan assistance for small businesses and
other eligible entities. EIDL proceeds could be used to pay fixed debts, payroll, accounts
payable, and other necessary financial obligations that could not be met as a direct result of
the disaster. Eligible applicants could also request and receive immediate advances of up to

$10,000, which did not have to be repaid.
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page 4of13

13. EIDL funds were issued directly from the United States Treasury, and applicants
could apply through the SBA via an online portal and application. The loan application
required the applicant to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain funds. The application required the applicant to
provide information about the business (such as the number of its employees and its gross
revenues for the 12-month period prior to the date of the disaster) and information as to any
criminal history of the business owner, among other information. Applicants were required to
certify that the information provided in their applications was true and accurate, and applicants
were warned that any false statement or misrepresentation to the SBA may result in sanctions,
including criminal penalties.

Pandemic Unemployment Benefits

14. | Unemployment Insurance (“UI”) was a joint state and federal program that
provided monetary benefits to eligible lawful workers. Although state workforce agencies
(“SWAs”) administered their respective UI programs, they did so in accordance with federal
laws and regulations. UI payments (benefits) were intended to provide temporary financial
assistance to lawful workers who were unemployed through no fault of their own. Each state
set its own additional requirements for eligibility, benefit amounts, and length of time benefits
were paid. Generally, UI weekly benefit amounts were based on a percentage of the applicant’s
earnings over a base period. As mentioned above, the CARES Act expanded these benefits in
response to the COVID-19 pandemic by establishing the PUA, FPUC and LWAP.

15. The SWA for each state had a different title. In the State of California, the
California Economic Development Department, based in Sacramento, administered the UI

program. In the State of Arizona, the Arizona Department of Economic Security, based in

4
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page5of13

Phoenix, Arizona, administered the UI program. In the State of Louisiana, the Louisiana
Workforce Commission (“LWC”), based in Baton Rouge, Louisiana, administered the UI
program.

16. Those seeking UI benefits submitted online applications to the SWAs.
Applicants had to answer specific questions to establish eligibility to receive UI benefits,
including their name, date of birth, telephone number and mailing address, among other things.
Applicants also had to self-certify that they met a COVID-19 related reason for being
unemployed, partially employed, or unable to work. The SWAs relied upon the information in
the applications to determine UI benefits eligibility. Once an application was approved, the
SWA typically distributed state and federal UI benefits electronically to a debit card or via
direct deposit. These debit cards were sent via the mail to the address the claimant provided.
The claimant could activate their debit card via telephone or online.

COUNT 1
Conspiracy to Commit Wire Fraud
(18 U.S.C. § 1349)

17. Beginning in or around April 2020, and continuing until at least November
2021, in the Middle District of Louisiana and elsewhere, the defendants, MICHELLE W.
JACKSON, a.k.a. “Michelle Walters Jackson,” and RYACHANELLE L. MORRIS, did
knowingly and willfully conspire and agree with each other, and with others known and
unknown to the grand jury, to commit wire fraud, that is, to devise a scheme to defraud the
United States, the PPP lenders, the state of California, the state of Arizona, the state of
Louisiana, and others, and to obtain money and property by false and fraudulent

representations, pretenses, and promises in relation to and involving loan proceeds and benefits

authorized, transmitted, disbursed, and paid in connection with a presidentially-declared major

5
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page 6of13

disaster or emergency (as those terms are defined in section 102 of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act (42 U.S.C. § 5122)), in violation of Title 18,
United States Code, Section 1343, as set forth more specifically below.

Object of the Conspiracy

18. The object and purpose of the conspiracy was for the conspirators to unjustly
enrich themselves by obtaining COVID-19 disaster relief and UI related proceeds to which
they were not entitled, under false and fraudulent pretenses including by submitting false and
fraudulent online PPP, EIDL, PUA, and UI applications, and other related documents.

Manner and Means

19. In order to accomplish the object and purpose of the conspiracy, JACKSON
and MORRIS, and their co-conspirators used and caused others to use, the following manner
and means, among others:

20. Beginning at least in or around April 2020, and continuing through at least in or
around November 2021, JACKSON and MORRIS, and their co-conspirators submitted, and
caused to be submitted, false and fraudulent PPP, EIDL, PUA, and UI applications.

21. Inmany of these PPP and EIDL applications, JACKSON and MORRIS, and
their co-conspirators each provided to the PPP lenders and the SBA false representations
pertaining to their businesses including the amount of gross revenues, the average monthly
payroll, and the number of employees, and provided false tax records and bank statements in
support of the applications. JACKSON and MORRIS knew these representations were false
when these PPP and EIDL applications were submitted.

22. Inmany of these PUA and UI applications, JACIKKSON and MORRIS, and their

co-conspirators each falsely represented to the SWAs that the applicant (a) worked in that state
6
Case 3:26-cr-00089-JWD-SDJ

Document 1

during at least some part of 2019 or 2020, (b) did not work in other states during the specified

time period, and (c) had not applied for PUA or UI benefits in any other state during the

specified time period. JACKSON and MORRIS knew these representations were false when

they submitted the PUA and UI applications.

23. Specifically, JACKSON and MORRIS, and their co-conspirators filed, or

caused to be filed, the following PPP, EIDL, and PUA/UI applications, which contained the

false representations described below, among others:

Date Application | Applicant Name | Example of False Statements
April 5, 2020 EIDL MNR Total That JACKSON’s business, MNR
Services, LLC Total Services, LLC, had 2019 gross
revenues of $75,000.

May 15,2020 | EIDL MNR Total That JACKSON’s business, MNR

Services, LLC Total Services, LLC, had 2019 gross
revenues of $179,800.

June 29, 2020 | PPP Total SVC, Inc. | That JACKSON’s business, Total
SVC, Inc., had average monthly
payroll of $6,954 and six employees.

July 8, 2020 PPP MNR Total That JACKSON’s business, MNR

Services, LLC Total Services, Inc., had average
monthly payroll of $25,392, 2019
gross sales/receipts of $375,500, and
ten employees.

July 18,2020 | Arizona UI Ryachanelle L. That MORRIS was employed in

Morris Arizona from 2017 until March 12,
2020, and had not worked in any other
state from July 2018 until July 2020.

July 25,2020 | PPP Ryachanelle That MORRIS’ business,

Morris, LLC Ryachanelle Morris, LLC, had

average monthly payroll of $27,551,
ten employees, and paid out $272,200
in wages, tips, and other
compensation in 2019.
Case 3:26-cr-00089-JWD-SDJ

Document 1

08/12/26 Page 8 of 13

July 29, 2020

PPP

Michelle
Jackson, LLC

That JACKSON’s business, Michelle
Jackson, LLC, had average monthly
payroll of $26,226, fifteen employees,
and paid out $272,200 in wages, tips,
and other compensation in 2019.

August 11,
2020

California UI

Michelle Jackson

That JACKSON resided and worked

in California from April 1, 2019, until
February 28, 2020, for an employer in
Calabasas, California.

August 27,
2020

Louisiana UI

Ryachanelle
Morris

That MORRIS had not applied for UI
benefits in any other state other than
Louisiana within the last 12 months
and that she had not worked in two or
more states between 4/1/2019 and
3/31/2020.

October 22,
2020

Louisiana UI

Michelle Jackson

That JACKSON had not applied for
UI benefits in any other state other
than Louisiana within the last 12
months and that she had not worked

in two or more states between
7/1/2019 and 6/30/2020.

December 31, | EIDL Ryachanelle That MORRIS’ business,

2020 Morris Ryachanelle Morris, had nine
employees and 2019 gross revenues
of $89,393.

March 28, 2021 | PPP Ryachanelle That MORRIS’ business,

Morris Ryachanelle L. Morris, had three
employees and average gross income
of $190,800 in 2019.
April 17,2021 | PPP Ryachanelle That MORRIS’s business, dba Da
Morris Hood Rich Collection, had gross

income of $348,000 in 2019 anda
bank account at Financial Lender 2
that had been open since February
2020.

24. In reliance on the above listed false and fraudulent representations made in

support of pandemic relief applications as well as other fraudulent information, JACKSON

and MORRIS gained control of, and attempted to gain control of, more than $350,000.00 in

pandemic benefit funds.
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page9of13

25. JACKSON and MORRIS spent the funds they received on personal expenses
including shopping and dining out.

COUNTS 2 THROUGH 4
Wire Fraud
(18 U.S.C. § 1343)

26. The allegations contained in Paragraphs 1-25 are incorporated by reference
herein as factual allegations.

27. | Onor about the dates set forth below, in the Middle District of Louisiana and
elsewhere, for the purpose of executing and attempting to execute the aforementioned scheme
and artifice to defraud, MICHELLE W. JACKSON, a.k.a. “Michelle Walters Jackson,” the

defendant herein, did transmit and cause to be transmitted in interstate commerce the following

wire communications, among others:

An electronic deposit in the amount of $17,385.00
from Financial Lender 1’s computer servers located
outside the State of Louisiana to a Bank 1 account

July 2, 2020 | belonging to JACKSON in the Middle District of
Louisiana.
An electronic deposit in the amount of $63,479.00
from Financial Lender 1’s computer servers located
3 Tuly 10, 2020 outside the State of Louisiana to a Bank 1 account

belonging to JACKSON in the Middle District of
Louisiana.

An electronic deposit in the amount of $65,564.00
from Financial Lender 1’s computer servers located

4 July 31, 2020 outside the State of Louisiana to JACKSON’s Bank 2
account in the Middle District of Louisiana.

Each of the above is a violation of Title 18, United States Code, Section 1343.
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page 10 of 13

NOTICE OF FORFEITURE

28. The allegations contained in Paragraphs 1-27 of this Indictment are hereby re-
alleged and incorporated by reference for the purpose of alleging forfeitures pursuant to Title
18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section
2461(c).

29. Upon conviction of MICHELLE W. JACKSON, a.k.a. “Michelle Walters
Jackson,” and RYACHANELLE L. MORRIS, the defendants herein, on Count One of the
Indictment or upon conviction of JACKSON, the defendant herein, on Counts Two through
Four of this Indictment, JACKSON and MORRIS shall forfeit to the United States pursuant
to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section
2461(c), all property, real or personal that constitutes or is derived from proceeds traceable to
the offenses, including but not limited to a sum of money equal to the amount of the proceeds
of the offenses.

30. If any of the property described above, as a result of any act or omission of the
defendant:
a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided
without difficulty,

10
Case 3:26-cr-00089-JWD-SDJ Document1 08/12/26 Page 11of13

it is the intent of the United States to seek a forfeiture money judgment and, pursuant 21 U.S.C.
§ 853(p) as incorporated by 28 U.S.C. § 2461(c), to seek the forfeiture of any other property

of the defendants up to the value of the forfeitable property described above.

UNITED STATES OF AMERICA, BY A TRUE BILL
— ff / REDACTED
= Wa Ss A oF PER PRIVACY ACT
KURT WALL : GRAND JURY FOREPERSON
UNITED STATES ATTORNEY

MIDDLE DISTRICT OF LOUISIA

J. BRADY CASEY DATE O
ASSISTANT UNITED STATES ATTORNEY

1]
Case 3:26-cr-00089-JWD-SDJ Document 1

Criminal Cover Sheet

08/12/26

Page 12 of 13
U.S. District Court

Place of Offense: Matter to be sealed:
City; Baton Rouge Related Case Information:
County/Parish: East Baton Rouge Superseding [ | Docket Number
Same Defendant [| New Defendant [ |
*Investigating Agency: OIG Magistrate Case Number:
Search Warrant Case No.:
*Agent: Thomas Redman R 20/ R 40 from District of:

Any Other Related Cases:

Defendant Information:

Defendant Name: MICHELLE W. JACKSON

[V] Yes [ | No

Alias; Michelle Walters Jackson

Address:

DOB: SS / Alien#: Sex: Race: Nationality:

U.S. Attorney Information:

AUSA: J. Brad Casey Bar #; L-BN 24338

Interpreter: [_]ves [V |No List language and/or dialect:

Location Status:

Arrest Date:

[] Already in Federal Custody as of

[] Already in State Custody

[ On Pretrial Release

U.S.C. Citations: Mandatory Minimum Charged?

Total # of Counts: 4 [ ] Yes No
Petty/

Code Description of Offense Charged Count(s) Misdemeanor/

Felony

18 U.S.C. § 1349 Conspiracy to commit wire fraud 1 F

18 U.S.C. § 1343 Wire fraud 2-4 r

(May be continued on second sheet)

Date: wal RO2 Signature of AUSA: > ae


File and source

File

1-sealed-indictment.pdf

Size

7,320,013 bytes

SHA-256

c28a5650ebf6d813ac725c4f278528c794db7e2c06585780b48b4e6cfe44e42c

Our copy

1-sealed-indictment.pdf

Original

storage.courtlistener.com