Memorandum and Order on Motion for Immediate Release and Government's Appeal of Release Order — United States v. Sniders Jean-Jacques et al. (Dkt. 51)

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A Memorandum and Order on Defendant's Motion for Immediate Release and the Government's Appeal of the Magistrate Judge's Order of Release, Document 51, dated April 20, 2026, in United States v. Sniders Jean-Jacques, Criminal Action Nos. 26-10030 and 26-10031-RGS, U.S. District Court for the District of Massachusetts. The court weighs the factors in 18 U.S.C. § 3142(g). It cites the government's estimate of a loss exceeding $13 million and a guideline range of 188 to 235 months, and concludes that no combination of conditions of release will ensure the defendant's presence for trial. The court denies the motion for immediate release, reverses the Magistrate Judge's release order and orders the defendant detained pending trial. It is signed /s/ Richard G. Stearns.

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     Case 1:26-cr-10031-RGS    Document 51   Filed 04/20/26     Page 1 of 4



                  UNITED STATES DISTRICT COURT
                   DISTRICT OF MASSACHUSETTS
         CRIMINAL ACTION NOS. 26-10030 and 26-10031-RGS

                     UNITED STATES OF AMERICA
                                     v.
                       SNIDERS JEAN-JACQUES

        MEMORANDUM AND ORDER ON DEFENDANT’S
             MOTION FOR IMMEDIATE RELEASE
  AND THE GOVERNMENT’S APPEAL OF THE MAGISTATE JUDGE’S
                  ORDER OF RELEASE

                              April 20, 2026

STEARNS, D.J.

     Defendant Sniders Jean-Jacques has been indicted in the District of

Massachusetts for bank and wire fraud conspiracy and, in a separate

indictment, for wire fraud conspiracy involving the alleged theft of funds

from the Covid-era Paycheck Protection Program.               Shortly after the

indictments were handed up, on February 9, 2026, Jean-Jacques was

arrested in Florida where he resides. After a detention hearing in the

Southern District of Florida, held on February 16, 2026, the Magistrate

Judge ordered defendant released on conditions but stayed the order

through February 18, 2026.    On February 17, 2026, the government filed an

emergency motion seeking a further stay, which this court allowed pending
        Case 1:26-cr-10031-RGS   Document 51    Filed 04/20/26   Page 2 of 4



defendant’s appearance in the District of Massachusetts.              Defendant

appeals the stay of the release order, while the government seeks revocation

of the release order.    The court held a hearing on the appeal on April 7,

2026.     In addition to the parties’ arguments and briefings, the court has had

the benefit of the Pretrial Services Report prepared in the Southern District

of Florida and the transcript of the hearing before Magistrate Judge Marty

Fulgueria Elfenbein. For the reasons stated below, the court will allow the

government’s motion to reverse the Magistrate Judge’s release order and

further order that the defendant be detained pending trial.

        Review of an order of detention or release by the district court is de

novo.     United States v. Tortora, 922 F.2d 880, 883 n.4 (1st Cir. 1990).

While the standard of review precludes deference to the Magistrate Judge’s

decision, comity requires that it be given consideration with respect. In

making its independent determination, the court is directed by 18 U.S.C. §

3142(g) and the case law to weigh the nature and circumstances of the

offense, the weight of the evidence, the history and characteristics of the

defendant, and any risk of flight or danger that might be posed to any person

or the community by defendant’s release. Risk of flight is decided by a

preponderance of the evidence, danger to the community by the stricter

standard of clear and convincing evidence.
                                     2
      Case 1:26-cr-10031-RGS    Document 51     Filed 04/20/26   Page 3 of 4



      With respect to the first three considerations, while wire fraud and

conspiracy are not per se crimes of violence, defendant’s situation is

complicated by the fact that he has been previously convicted of virtually the

same crimes (for which he served a two-year federal sentence) when the

present crimes were allegedly hatched.        That reality and the scale of his

alleged crimes, which resulted in a loss that, by the government’s estimate,

exceeds $13 million dollars, will expose him if convicted to a guideline

sentencing range of 188 to 235 months.         That prospect alone provides a

powerful incentive to flee.

      The defendant’s history of appropriating the identities of others (an

integral facet of his criminal activity) and his deep roots in Haiti further

enhance the likelihood of flight.   While Jean-Jacques is a U.S. citizen, as the

government points out, his roots in the Florida community in which he

resides are weak. He is not married, and while he has children, he is

estranged from them and their current custodial mother (who is suing him

for child support).   He does not own a home and, by all appearances, has no

permanent address.      For all these reasons, I conclude that there are no

combination of conditions of release that will ensure defendant’s presence




                                       3
        Case 1:26-cr-10031-RGS   Document 51    Filed 04/20/26   Page 4 of 4



for trial. 1

       For the foregoing reasons, defendant’s motion for immediate release is

DENIED.        The order of release entered by the Magistrate Judge is reversed

and the defendant ordered detained pending trial.



                                      SO ORDERED.

                                      /s/ Richard G. Stearns
                                      UNITED STATES DISTRICT JUDGE




       1While the government argues (with support in cases from other
circuits), that economic as well as violent crimes can be weighed in a danger
to the safety of the community analysis, see United States v. Cook, 880 F.2d
1158, 1161 (10th Cir. 1989), I need not consider this ground for detention
given the strength of the case for a likelihood of flight. I have considered
the allegations that defendant has made threats against others in the past,
including potential witnesses, and has been reported at times to be in
possession of a firearm, in considering his character. While these may not be
evidence per se of a proclivity to flee, they do tend to corroborate the
government’s contention that the defendant’s regard for the law, including
the likelihood of his abiding by conditions of release, is questionable.
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