Opinion — United States v. Zipora Hudson (5th Cir.)

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A per curiam opinion of the U.S. Court of Appeals for the Fifth Circuit, not designated for publication, in United States v. Zipora Hudson, No. 25-60247, filed March 25, 2026 as Document 61-1, before Circuit Judges Haynes, Higginson and Ho. Hudson, owner of the Zippy Bee tax service, appealed her conviction in the Northern District of Mississippi, where the jury convicted Zipora Hudson and Montreal Hudson of conspiracy to commit wire fraud and conspiracy to commit money laundering over PPP loans; she challenges only the sufficiency of the evidence. The opinion recounts trial evidence that she referred clients who did not qualify to her son, Montreal Hudson, to complete loan applications, that clients paid approximately $2,000 kickbacks per loan, and that she bought a Maserati for $88,999. The court holds a reasonable jury could find her guilty on both counts and affirms.

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“Opinion — United States v. Zipora Hudson (5th Cir.).” Original at www.govinfo.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-25-60247-dkt-61-1-5th-cir-f11140e2a1/, SHA-256 6d1f34f1726cd440587e5af191514bb5020ee55f82ddc443658dfe70e5e02fb3.

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Case: 25-60247 Document: 61-1 Page: 1 Date Filed: 03/25/2026

United States Court of Appeals
for the Fifth Circuit
____________ United States Court of Appeals
Fifth Circuit

FILED
No. 25-60247 March 25, 2026
____________
Lyle W. Cayce
United States of America, Clerk

Plaintiff—Appellee,

versus

Zipora Hudson,

Defendant—Appellant.
______________________________

Appeal from the United States District Court
for the Northern District of Mississippi
USDC No. 3:24-CR-5-1
______________________________

Before Haynes, Higginson, and Ho, Circuit Judges.
Per Curiam: *
Zipora Hudson appeals her conviction for conspiracy to commit wire
fraud and conspiracy to commit money laundering. She challenges only the
sufficiency of the evidence supporting her conviction. Because a reasonable
jury could find her guilty on both counts, we affirm.

_____________________
*
This opinion is not designated for publication. See 5th Cir. R. 47.5.
Case: 25-60247 Document: 61-1 Page: 2 Date Filed: 03/25/2026

No. 25-60247

I.
Zipora Hudson was indicted for conspiracy to commit wire fraud in
violation of 18 U.S.C. §§ 1349 and 1343, and conspiracy to commit money
laundering, in violation of 18 U.S.C. §§ 1956(h) and (a)(1). 1 At trial, the
government presented the following evidence:
Hudson owned Zippy Bee tax service. She employed her son,
Montreal Hudson, and two other individuals, Deandre Jones and Carolyn
Jones. Hudson had numerous long-time clients for whom she had provided
tax services for many years.
In addition to preparing her clients’ taxes, Hudson also began
consulting with clients about their eligibility for Paycheck Protection Plan
(“PPP”) loans. 2 After discussing the loans, she referred clients to her son,
Montreal, to complete the PPP loan paperwork. Hudson recommended
these clients apply for PPP loans despite knowing they didn’t qualify.
Montreal Hudson then completed these clients’ loan applications without
asking them for any of the requisite application information.
Clients were charged approximately $2,000 for each fraudulent PPP
loan they received. Clients paid these loan “kickbacks” directly to either
Montreal Hudson or Carolyn Jones. At trial, multiple clients testified that
they knew very little about the PPP loan eligibility requirements and that they

_____________________
1
Hudson was indicted on five additional counts, but the government moved to
dismiss these additional counts at the close of trial.
2
“During the COVID-19 pandemic, Congress created the Paycheck Protection
Program [] to help eligible small businesses maintain payroll amid government shutdowns
of the economy. See Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116–
136, § 1102, 134 Stat. 281, 286–94 (2020).” Bruckner Truck Sales, Inc. v. Guzman, 148 F.4th
341, 344 (5th Cir. 2025).

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No. 25-60247

had simply followed Hudson’s advice and applied for the loans with
Montreal Hudson’s help.
Following the close of evidence, the jury convicted Zipora Hudson
and Montreal Hudson of conspiracy to commit wire fraud and conspiracy to
commit money laundering. Zipora Hudson moved the court for a judgment
of acquittal following the government’s close of evidence and again after
resting her defense. The court denied both motions. She then filed a motion
for a judgment of acquittal and a motion for new trial, which the court denied.
She now appeals her conviction, arguing that the jury lacked sufficient
evidence to convict her.
II.
Because Hudson properly preserved her challenge to the sufficiency
of the evidence, our review is de novo. See United States v. Percel, 553 F.3d
903, 910 (5th Cir. 2008); Fed. R. Crim. P. 29(a), (c)(1).
“[R]eview of a sufficiency-of-the-evidence challenge is highly
deferential to the verdict.” United States v. Najera Jimenez, 593 F.3d 391, 397
(5th Cir. 2010) (cleaned up). Any defendant “seeking reversal on the basis
of insufficient evidence swims upstream.” United States v. Mulderig, 120
F.3d 534, 546 (5th Cir. 1997). We will uphold the jury’s verdict if a
reasonable trier of fact could conclude from the evidence that the elements
of the offense were established beyond a reasonable doubt. Jackson v.
Virginia, 443 U.S. 307, 319 (1979). “The evidence need not exclude every
reasonable hypothesis of innocence or be wholly inconsistent with every
conclusion except that of guilt.” Najera Jimenez, 593 F.3d at 397 (cleaned
up).
Hudson contends that the jury lacked sufficient evidence to convict
her on both counts. We address each challenge in turn.

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No. 25-60247

III.
Hudson first challenges the sufficiency of the evidence underpinning
her conviction for conspiracy to commit wire fraud. Notably, she doesn’t
contest that wire fraud occurred. Rather, she argues that the government
failed to present any evidence that she was aware of or involved in the fraud.
To establish conspiracy to commit wire fraud, the government must
prove that “(1) two or more persons made an agreement to commit wire
fraud; (2) the defendant knew the unlawful purpose of the agreement; and
(3) the defendant joined in the agreement willfully, i.e., with specific intent.”
United States v. Kuhrt, 788 F.3d 403, 414 (5th Cir. 2015).
“Criminal conspiracies can be established on circumstantial evidence
alone.” United States v. Sanders, 952 F.3d 263, 273 (5th Cir. 2020). In fact,
“a jury can infer from the surrounding circumstances whether a defendant
participated in and knew of the conspiracy.” Id. The “central feature of a
conspiracy is the agreement, but it doesn’t need to be formal or even spoken.
It can be inferred from concert of action.” Id. at 274 (internal citations
omitted). But “[m]ere similarity of conduct among various persons and the
fact that they have associated with or are related to each other is insufficient
to prove an agreement.” United States v. Ganji, 880 F.3d 760, 767–78 (5th
Cir. 2018) (cleaned up).
Here, the government produced evidence that Hudson was not only
aware of the fraud perpetrated by Montreal Hudson, but that she also actively
participated in and furthered the fraud. The government presented evidence
that Hudson discussed PPP loan applications with two long-time clients,
Gloria Ealy and Debra Armstrong, despite knowing that neither individual
owned a requisite business. Regardless, she directed both individuals to
Montreal Hudson to complete PPP loan paperwork. Similarly, Sherry
Simmons testified at trial that she met with Hudson to discuss PPP loans and

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No. 25-60247

that Hudson directed her to Montreal Hudson to complete the loan
paperwork, despite knowing that she didn’t qualify for PPP loans.
Furthermore, the government presented evidence that Hudson
orchestrated and directed the loan kickbacks paid by clients. Ezell Cashaw
testified that, when one of his PPP loan applications was flagged as
fraudulent, he requested Zippy Bee refund the $2,000 kickback he had
already paid. Deandre Jones told Cashaw that he would have to ask Hudson
for permission to repay the kickback.
Based on this evidence, a reasonable jury could have found that
Hudson not only knew that Montreal Hudson was processing fraudulent PPP
loans but also that she actively facilitated and directed this fraud.
IV.
Hudson next challenges the sufficiency of the evidence underpinning
her conviction for conspiracy to commit money laundering. She does not
contest that money laundering occurred. Rather, she challenges only
whether the government proved that she was aware of the money laundering
and participated in it.
To establish a conspiracy to commit money laundering, the
government must prove beyond a reasonable doubt that (1) “there was an
agreement between two or more persons to commit money laundering,” and
(2) “that the defendant joined the agreement knowing its purpose and with
the intent to further the illegal purpose.” United States v. Alaniz, 726 F.3d
586, 601 (5th Cir. 2013).
Here, the government presented evidence that Hudson was not only
aware that the wire fraud proceeds were being laundered through Zippy Bee,
but also that she actively participated in laundering those proceeds. For each
fraudulent PPP loan received, Hudson’s clients paid approximately $2,000

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No. 25-60247

directly to either Montreal Hudson or Carolyn Jones. Ezell Cashaw testified
that Hudson was not only aware of these kickbacks, but that she also had the
final say whether clients could receive refunds. Furthermore, the
government presented evidence that Hudson personally benefited from the
fraud. During the time Hudson was perpetrating PPP loan fraud, both
Hudson and Montreal Hudson made lavish purchases. Hudson purchased a
Maserati for $88,999 and Montreal Hudson purchased two residences.
Based on this evidence, a reasonable jury could have found that
Hudson not only knew that illegal kickbacks were being laundered through
Zippy Bee but also that she actively participated in the money laundering.
* * *
Because the government presented sufficient evidence for a
reasonable jury to find Hudson guilty on both counts, the judgment of the
district court is affirmed.

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