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Home Source documents Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 1018, D. Minn.)

Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 1018, D. Minn.)

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     CASE 0:22-cr-00223-NEB-DTS            Doc. 1018     Filed 08/24/26        Page 1 of 9




                  UNITED STATES DISTRICT COURT
                       DISTRICT OF MINNESOTA
________________________________________________________________________

UNITED STATES OF AMERICA,                         Court File No. 22-cr-223 (09)(NEB/DTS)

                     Plaintiff,

v.                                                        DEFENDANT’S POSITION
                                                          ON SENTENCING
ABDIKADIR AINANSHE MOHAMUD,

                 Defendant.
________________________________________________________________________

       The Defendant, Abdikadir Mohamud, respectfully submits his position on

sentencing and requests a downward variance for the reasons set forth herein. He presents

several mitigating factors that weigh against imposing a strict guidelines sentence despite

the seriousness of the offense.

       Mohamud has been on pretrial supervision since September, 2022 without any

problems. During the last four years, he has continued his education and maintained

employment. He and his wife welcomed two children into their family since he was

charged in this case. The youngest child has a genetic disorder and requires signi cant

care that will continue for her lifetime. Mohamud comes before the Court with signi cant

stress not just about his daughter’s well-being, but more so about his ability to care for her

and to provide for his family.

       Meanwhile, public sentiment about the overall Feeding Our Future prosecution

has become increasingly hostile as the case has been politicized. There is understandable

resentment about the staggering amount of money diverted from the public good during


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a pandemic that disrupted everyone’s lives. However, Mohamud and many in the East

African community, are increasingly worried about their safety both in terms of attitudes

toward their community, families, and themselves personally. The current political

environment essentially encourages people to give in to hatred of all East African

immigrants. Political gures openly foment ant-Somali attitudes and suggest collateral

consequences for Minnesotans of Somali descent.1 Vague references to fraud in

Minnesota formed the initial impetus for the surge of ICE agents into our state.2

       Certainly, this charged rhetoric is problematic in many ways. It is now part of the

political discourse in Minnesota precisely because opportunistic politicians want to exploit

the genuine concern many people have about the breadth of the instant case. The Court

is surely cognizant of this situation. Counsel would typically argue the Court should

ignore the context of public opinion in terms of determining what is suf cient, but not

greater than necessary to achieve the goals of federal sentencing. In the instant case, a just

punishment for the offense should contemplate unknown extrajudicial consequences that

will affect Mohamud well into the future.

       Mohamud recognizes the sentencing considerations in this matter generally

concern retribution for an egregiously large scale fraud versus a sentence that focuses

primarily on the rehabilitation of offenders. This Court has always endeavored to fashion

appropriate sentences in consideration of the unique circumstances of each defendant

1 https://www.pbs.org/newshour/politics/watch-trump-says-he-doesnt-want-somali-migrants-
in-the-u-s-calls-people-garbage; https://www.washingtonpost.com/nation/2026/01/21/trump-
davos-somali-intelligence/
2 cf. https://www.pbs.org/newshour/nation/a-timeline-of-trumps-immigration-crackdown-in-
minnesota

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and with due regard for the law. Mohamud humbly asks the Court to consider a sentence

below the advisory guideline range, allowing him to be placed on home con nement as

soon as possible. Mohamud is unlikely to reoffend or commit new offenses based on his

lack of criminal history and his positive characteristics. He should be considered a low

risk offender.

                                  PSR CALCULATION

       Mohamud has no outstanding objections to the PSR that require Court action. He

fully accepted responsibility for his role in the offense and he did not le objections to the

recommended guideline range since it did not differ from the plea agreement. The total

offense level should be 24 in criminal history category I. The advisory range is 51-63

months.

       The only area of controversy in the PSR concerns Mohamud’s separation from his

employment with WorldWide Language Resources in paragraph 147. Mohamud

maintains he left this employment and was not terminated. He agrees there was a dispute

regarding authorized travel off the military base where he was stationed, but he denies

walking off the job. He claims the separation was amicable and not a termination of

employment. Mohamud was offered another linguist position through a related

employment agency in 2021. He fears the form provided to the US Probation Of ce by

WorldWide was improperly created after his separation. This distinction is important to

Mohamud because he wants to be depicted accurately before the Court.

       There are no other objections to the PSR.



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                                          BACKGROUND

            Abdikadir Mohamud was born in Ethiopia, but he speaks the Somali language. He

     immigrated to Kenya with his family when he was a toddler. His mother passed away

     during this transition to Kenya. Mohamud was raised by his stern and detached father

     along with his extended family. His time in Kenya was fraught with danger due to his

     living arrangements in a high crime area. Mohamud’s reluctance to regularly attend

     religious school often resulted in physical punishment. During the PSR interview,

     Mohamud became emotional recounting a series of sexual assaults involving his uncle in

     Kenya.

            Mohamud moved to the United States with his father when he was twelve years

     old and settled initially in Ohio. He moved to Minnesota before high school, and drifted

     apart from his father. Mohamud embraced his new life in the United States, which fueled

     the split from his more traditional father. Eventually, Mohamud moved to Minnesota and

     lived with an aunt. The living arrangements in Minnesota were not ideal as Mohamud

     was not treated as an equal to his extended family. Despite the uncomfortable

     surroundings, Mohamud loved attending school and showed pro ciency in many areas.

     He is uent in four languages.

            Upon graduation, Mohamud joined the United States Navy and served four years

     active duty. He was honorably discharged at the rank of E3 and received several awards

     or commendations. Mohamud’s linguistic skills served him well in the Navy and beyond.

     Following his military service, he secured employment as a linguist for a translation

     service supporting U.S. special forces operators in Africa.

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            Mohamud returned to Minnesota in 2020 and found employment quickly. It was

     during this time he became involved in the activities associated with the instant case.

     Mohamud recalls the opportunity to join the Feeding Our Future program was presented

     to him by others already involved in the scheme. Initially, the program appeared to be

     legitimate and Mohamud believed it was both a means of earning income and doing

     good. He claims it didn’t take long for him to realize the true nature of the program and

     those involved in it. Mohamud will forever regret his decision not to walk away from the

     scheme when he had a chance. In his acceptance statement, Mohamud expressed

     tremendous remorse. He made the decision to go all in with his co-defendants. He feels

     he let more than just his family down as a person who served our country honorably in

     the military. He knew better than to get involved in something so wrong, but he was

     blinded by the lure of what seemed like easy money while being encouraged by others.

     He was making decent income and could’ve gone back to a linguistics job in 2021 before

     he got involved with Feeding Our Future.

            Since the instant case was charged, Mohamud’s wife has given birth to two

     children. He now has a total of seven children. He and his wife are both educated and

     they work hard to provide for their family. The youngest child has a genetic disorder that

     prevents her from eating or drinking on her own. She spent the majority of her rst year

     in the hospital. The prognosis for this child is generally positive, but she will require

     signi cant special needs for the rest of her life. Mohamud was still able to pursue higher

     education all while facing the instant prosecution and the stress of caring for his youngest

     child. He enrolled at Augsburg in Minneapolis in 2024 to study mechanical engineering

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     and he was recently accepted to the University of Minnesota for the same program. This

     is no small feat given the circumstances, but Mohamud is an intelligent and very hard

     working. He expresses a strong desire not to be a burden on the state.

            While preparing this brief, it was hard to gauge the extent of how Mohamud

     pro ted from the fraud. After everything, he still has a mortgage on his home, which he

     purchased well before this case began. He lives modestly and did not purchase ashy

     jewelry or cars. This is not to say he didn’t enjoy the proceeds of his involvement. But in

     comparison to other defendants, he acted more conservatively with the money. Any

     money he had in bank accounts and his interest in a commercial real estate deal was

     forfeited. His family gets by paycheck to paycheck.

            Mohamud comes before the Court having recent surgery for Arnold-Chiari

     malformation, which affects how the cerebellum meets the upper spinal canal.3 The

     surgery was a success and the expectation is that Mohamud will recover. However, he will

     require regular follow-up appointments and medication. The Bureau of Prisons is no

     longer equipped to properly handle medical issues. Budget cuts and chronic understaf ng

     in the BOP make Mohamud’s medical treatment dangerous and costly.4 He is also

     vulnerable as an inmate due to his condition should he nd himself confronted with

     violence in a BOP facility or if his condition requires immediate attention.




     3 https://www.mayoclinic.org/diseases-conditions/chiari-malformation/symptoms-causes/
     syc-20354010
     4 https://www.forbes.com/sites/walterpavlo/2025/11/21/deputy-director-of-bureau-of-prisons-
     describes-agency-on-the-brink/

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                                       ARGUMENT

       Mohamud respectfully requests a sentence below the advisory guideline range due

to his lack of criminal history, his military service history and otherwise positive

characteristics, his family support, showing of remorse, and his commitment to providing

for his family. He will have a restitution order that will stretch his punishment well into the

future as he attempts to satisfy the amount due. And, Mohamud has not only the

consequence of a felony record, but the scarlet letter of being associated with one of

Minnesota’s most publicized fraud cases.

       The Sentencing Reform Act of 1984 (Title II of the Comprehensive Crime

Control Act of 1984) provides that a sentencing court “shall impose a sentence suf cient,

but not greater than necessary, to comply with” the purposes of sentencing: (1) to re ect

the seriousness of the offense, to promote respect for the law, and to provide just

punishment for the offense; (2) deterrence; (3) protection of the public from further

crimes; and (4) rehabilitation. See 18 U.S.C. § 3553(a). The 2025 amendments to the

United States Sentencing Guidelines manual streamlined federal sentencing methodology.

The 2025 version states in §1B1.1, there is a two step process: First, Courts must calculate

the guideline range and determine sentencing requirements and options pursuant to the

guidelines manual. Second, the Court must consider the factors set forth in 18 U.S.C.

§3553(a). Traditional departures that appeared in the guidelines previously are now

considered within the §3553(a) factors.

       After calculating a defendant’s advisory sentencing guidelines range and hearing

from the parties, the district court must consider the sentencing factors set forth in 18

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U.S.C. §3553(a) and make an individualized assessment based on the facts arriving at an

appropriate sentence. Gall v. United States, 552 U.S. 38, 49-50 (2007). The district court

“has wide latitude to weigh the [18 U.S.C.] section 3553(a) factors in each case and assign

some factors greater weight than others in determining an appropriate sentence.” United

States v. Richart, 662 F.3d 1037, 1054 (8th Cir. 2011). Mohamud argues the §3553(a)

factors, taken as a whole, support a downward variance below the guideline range. He

seeks the ability to be placed on home con nement at the earliest time practicable

because he has the ability to maintain employment, provide necessary care for his

children, and complete his education in an effort to better himself. Mohamud also seeks

the ability to obtain medical care for himself without placing a further burden on

taxpayers.

       Mohamud has no criminal history beyond simple traf c or parking violations. He

has no history of substance abuse. By most metrics, he is highly likely to remain law

abiding. Mohamud has an honorable military service history that bodes well for his ability

to be successful on supervised release and beyond. While his service alone should not be

viewed as a “pass” for criminal behavior, it is important to note how he served. Mohamud

enlisted in the Navy and served four years. But then he signed up to provide direct

support to special forces operations in danger zones. These jobs do not go to unquali ed

or untrustworthy people. This is why Mohamud feels so much remorse for his actions

now- he made himself untrustworthy. Yet, he is presently working hard to rebuild his life

and prove he can be trusted to contribute to our community rather than just take from it.



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       The judiciary sentencing data in the PSR indicates the average (and the median)

length of imprisonment for similar offenders nationwide is 41 months. The facts of the

instant case are perhaps unique just in terms of the loss amount. Mohamud argues the

individual assessments of the various offenders nationwide would suggest a sentence in

the guideline range is greater than necessary since many received a reduction.

       Mohamud has a big family to care for and a large restitution amount to pay off. A

purely punitive sentence of lengthy imprisonment may send a message of deterrence and

respect for the law, but it also punishes more than just Mohamud. The community does

not need to be protected from possible future crimes by this individual. Rather, he seeks to

make amends for his crime by paying on his debt and positively contributing to society.

The collateral consequences of this case will follow Mohamud perhaps the rest of his life.

He respectfully asks the Court to consider the mitigating factors presented and give him

the ability to pay back the people of Minnesota.

                                          Law Of ce of Robert A. Lengeling, PLLC

Date:__August 24, 2026___                 By ___s/ Robert A. Lengeling______________
                                                MN ID# 304165
                                                Lumber Exchange Building
                                                10 S. 5th Street, Suite 800
                                                Minneapolis, Minnesota 55402
                                                (612) 963-1555
                                                robert@lengelinglaw.com
                                                ATTORNEY FOR DEFENDANT




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