Government's Sentencing Memorandum — United States v. Kisha Sutton (Southern District of West Virginia)
Summary
The government's sentencing memorandum in United States of America v. Kisha Sutton, Criminal No. 2:24-CR-00192-1, in the United States District Court for the Southern District of West Virginia, filed November 18, 2025 as Document 415. Under 18 U.S.C. § 3553(a), the government asks for 37 months' imprisonment and 5 years' supervised release, a fine of $10,000, restitution of $184,014.04 and a forfeiture money judgment of $3,000. The memorandum calls the defendant the ringleader of a scheme to defraud financial institutions and the United States Small Business Administration through Paycheck Protection Program loans sought for friends and family with false tax forms, followed by kickbacks through Cash App. It states that probation is unavailable because bank fraud is a Class B felony. It is signed s/Jonathan T. Storage.
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“Government's Sentencing Memorandum — United States v. Kisha Sutton (Southern District of West Virginia).”
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Case 2:24-cr-00192 Document 415 Filed 11/18/25 Page 1 of 5 PageID #: 2747
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON
UNITED STATES OF AMERICA
v. CRIMINAL NO. 2:24-CR-00192-1
KISHA SUTTON
GOVERNMENT’S SENTENCING MEMORANDUM
Comes now the United States of America, by Jonathan T.
Storage, Assistant United States Attorney for the Southern
District of West Virginia and submits this Sentencing Memorandum
in aid of sentencing.
I. SENTENCING FACTORS
The United States offers the following analysis relating to
the application of the sentencing factors enumerated in 18 U.S.C.
§ 3553(a). As discussed below, the government requests that the
Court sentence the defendant to 37 months’ imprisonment, to be
followed by 5 years’ supervised release. The government further
requests the Court impose a fine of $10,000, order restitution in
the amount of $184,014.04, and order a forfeiture money judgment
in the amount of $3,000.
A. History and Characteristics of the Offender
The defendant grew up in Brooklyn, New York, living
predominately with her great aunt. From 2003 to 2018, the
Case 2:24-cr-00192 Document 415 Filed 11/18/25 Page 2 of 5 PageID #: 2748
defendant lived in West Virginia. She has 4 siblings and 2
children. She is currently single and lives in Brooklyn, New York.
From age 13 until her arrest in this case, she used marijuana
daily. She has a GED and an associate’s degree. She has worked in
the healthcare field for nearly 20 years.
B. Nature and Circumstances of the Offense
The Court is well acquainted with the facts of this case. The
defendant was the ringleader in a large scheme to defraud various
financial institutions and the United States Small Business
Administration. Until she got caught, her scheme was very
successful. The defendant solicited friends and family to allow
her to apply for Paycheck Protection Program (“PPP”) loans on their
behalf. Sadly, she convinced many individuals, now co-defendants,
to go along with the plan.
Of course, none of the individuals she solicited qualified
for a PPP loan, and the defendant knew this. Undeterred by facts,
she made up details about her co-defendants to ensure that, on
paper, they qualified for the loans. She created false tax forms
and loan applications – completely making up income and business
expenses for her co-defendants.
Once the loan applications were completed and submitted, she
waited with her co-defendants to learn whether the loans were
approved. When they were approved, she provided her co-defendants
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Case 2:24-cr-00192 Document 415 Filed 11/18/25 Page 3 of 5 PageID #: 2749
with instructions on how to compensate her for obtaining “free
money” for them. In other words, she expected and directed kickback
payments.
The kickback payments were not so straightforward. To conceal
the true nature and source of the money, she directed her co-
defendants to pay her through Cash App, admonishing them to break
up the payments. In some instances, as with co-defendant Shamiese
Wright, her co-defendants wrote “memos” for the kickback payments
that were wholly unrelated to their true purpose.
Thus, the defendant conceived, organized, and implemented a
full-throated bank fraud and money laundering scheme to steal money
from the federal government.
C. Seriousness of Offense, Deterrence, and Community
Protection
The defendant systematically executed a multi-party financial
scheme over a period of several months - no small feat for a person
with no documented criminal history. Her criminal conduct was
premeditated and consistent. Her actions are not indicative of
some one-off slip in judgment; she recruited her co-defendants and
directed the scheme.
More than anyone else who the United States Attorney’s Office
for the Southern District of West Virginia has prosecuted for PPP
loan fraud, Kisha Sutton is deserving of time in prison. Kisha
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Sutton is the kind of defendant judges in this district have been
asking about: “What is being done about the people who have lured
in our West Virginia residents with the promise of free COVID
money?” Well, Kisha Sutton is one such exploiter.
The defendant’s offense is very serious, and she should be
punished in a way that reflects her leadership role in the scheme.
Moreover, she helped create felons out of individuals who otherwise
had no (or no meaningful) criminal histories. A message of strong
deterrence is necessary for the defendant and any would-be
defendant of her kind.
D. Sentencing Options
Because the bank fraud conviction is a Class B felony, a term
of probation is unavailable. The government submits that a term of
37 months’ imprisonment accurately reflects the seriousness of the
defendant’s conduct, would deter future offenses, and would not be
greater than necessary to meet all of the other purpose of
sentencing. The government requests that the defendant’s term of
imprisonment be followed by a supervised release term of 5 years.
Restitution in the amount of $184,014.04 and a forfeiture money
judgment in the amount of $3,000 should be ordered, along with a
fine of $10,000.
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II. CONCLUSION
The government submits that the requested would be sufficient
but not greater than necessary to meet the purposes of sentencing.
Respectfully submitted,
MOORE CAPITO
United States Attorney
By:
s/Jonathan T. Storage
JONATHAN T. STORAGE
Assistant United States Attorney
WV State Bar No. 12279
300 Virginia Street, East
Room 4000
Charleston, WV 25301
Telephone: 304-345-2200
Fax: 304-347-5104
E-mail: Jonathan.Storage@usdoj.gov
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