Indictment — United States v. Scott Christie, Southern District of West Virginia (Document 1)

Summary

A grand jury indictment of Scott Christie, Case No. 3:24-cr-00107, in the U.S. District Court for the Southern District of West Virginia, filed July 9, 2024 as Document 1. It charges theft of government money under 18 U.S.C. § 641. The indictment alleges that Christie filed valid unemployment claims with WorkForce West Virginia on February 10, 2020 and February 7, 2021, returned to work weeks later, and then falsely certified on 52 different weeks that he was unemployed. It states that Key Bank loaded weekly Unemployment Compensation onto debit cards for 52 weeks aggregating to $34,801.00, including federal FPUC funds created by the CARES Act.

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Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 1 of 6 PagelD #: 1

| FILED

UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF WEST VIRGINIA JUL - 9 2024
CHARLESTON GRAND JURY 2024
JULY 9, 2024 SESSION "FOE FERRY TOLER

Southem bis District of West Virginia

UNITED STATES OF AMERICA

v. CRIMINAL NO. 3. 24-c-- 00/07
18 U.S.C. § 641
SCOTT CHRISTIE
INDICTMENT
The Grand Jury charges:
Introduction

1. From approximately February 29, 2020, through at least August 22, 2020, and from
approximately February 27, 2021, through at least August 14, 2021, defendant SCOTT CHRISTIE
defrauded the state of West Virginia and the United States of $34,801.00 in unemployment benefits
by submitting materially false unemployment claims.

2 After initially being qualified to receive Unemployment Compensation, defendant
SCOTT CHRISTIE became ineligible to receive unemployment benefits based on his resumption
of employment with his employer on two separate occasions. Nonetheless, defendant SCOTT
CHRISTIE falsely certified on 52 different weeks that he was unemployed and entitled to
Unemployment Compensation via the State of West Virginia’s website.

3. Based on defendant SCOTT CHRISTIE’S materially false unemployment
certifications, defendant SCOTT CHRISTIE received weekly Unemployment Compensation for

52 weeks aggregating to $34,801.00.
Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 2 of 6 PagelD #: 2

Background

4. Defendant SCOTT CHRISTIE was a resident of Leon, Mason County, West
Virginia, in the Southern District of West Virginia.

5. WorkForce West Virginia was a division of the West Virginia Department of
Commerce that was funded though the United States Department of Labor. WorkForce West
Virginia administered the “Unemployment Compensation” program in the state of West Virginia.

6. Unemployment Compensation (“UC”) was a joint state and federal program that
provided monetary benefits to eligible beneficiaries. UC benefits were intended to provide
temporary financial assistance to lawful workers who were unemployed through no fault of their
own.

7. Those seeking UC benefits in West Virginia submitted online applications to
WorkForce West Virginia. Applicants had to answer specific questions to establish eligibility to
receive UC benefits, including their name, Social Security Number (SSN), mailing address, and
other information. WorkForce West Virginia relied upon the information in the application to
determine UC benefits eligibility.

8. If WorkForce West Virginia approved a UC claim, the claimant could choose to
receive UC benefits by direct deposit or via debit card.

9. WorkForce West Virginia approved UC benefits using Key Bank, a financial
institution as defined in 18 U.S.C. § 20, and headquartered in Cleveland, Ohio.

10. All claimants that chose the debit card option would be mailed, via United States
Mail, a KeyBank debit card with the claimant's name on it based upon information received from

WorkForce West Virginia.
Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 3 of 6 PagelD #: 3

11. Once the initial application for UC benefits was approved, the claimant was
required to certify their continued eligibility for benefits every week. The certification process
occurred via the internet. The claimant was required to answer several questions, including, but
not limited to: (1) whether the Unemployment Compensation claimant had worked during the
certification period; (2) whether the claimant was able to work; (3) whether the claimant was
available for work; and (4) whether the claimant was actively looking for work during the
certification period.

12. WorkForce West Virginia would authorize continued UC benefits to a claimant
based on the claimant’s self-certified eligibility. If WorkForce West Virginia authorized the
benefits, Key Bank initiated a direct deposit into the claimant’s bank account or loaded funds on
to the claimant’s previously provided debit card, depending on the claimant’s election.

13. In March of 2020, in response to the COVID-19 pandemic, the federal government
enacted the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. The CARES Act,
among other things, provided additional flexibility and federal funding for state UC agencies,
including WorkForce West Virginia.

14. The Federal Pandemic Unemployment Compensation (““FPUC”) program was a
temporary unemployment insurance program created by the CARES Act. FPUC originally
provided individuals that received approved Unemployment Compensation with an additional
$600 per week in federal funds. In December of 2020, Congress reauthorized FPUC at a lesser
amount of $300 per week and concluded the program in September 2021.

15. From at least February 29, 2020, through August 22, 2020, and from at least
February 27, 2021, through August 14, 2021, defendant, SCOTT CHRISTIE, was employed by a

company known to the Grand Jury, in Cabell County, West Virginia.
Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 4 of 6 PagelD #: 4

The Scheme
16. Beginning on or about February 10, 2020, through at least August 22, 2020, and
beginning on or about February 7, 2021, through at least August 14, 2021, defendant SCOTT
CHRISTIE knowingly and willfully devised, and intended to devise, a scheme and artifice to
defraud WorkForce West Virginia and to obtain money from the United States by means of materially
false and fraudulent pretenses and representations and promises.

Manner and Means of the Scheme

17. On or about February 10, 2020, defendant SCOTT CHRISTIE used the WorkForce
West Virginia website to file for UC benefits claiming “lack of work” as his reason for
unemployment. In response to his claim, defendant SCOTT CHRISTIE was mailed a debit card
from Key Bank on or about February 11, 2020, that was loaded with weekly UC benefit funds,
subject to defendant SCOTT CHRISTIE’s continued certifications that he was unemployed.

18. Employment and wage records maintained by a company known to the Grand Jury
indicate that defendant SCOTT CHRISTIE’s claim was initially valid when made on February 10,
2020, but that he returned to work at a company known to the Grand Jury on or about February
29, 2020, and that he continued to be employed by a company known to the Grand Jury until at
least August 22, 2020. Between February 29, 2020, and August 22, 2020, defendant SCOTT
CHRISTIE submitted twenty-five (25) Benefit Week Ending date certifications (““BWE
certifications”) where he did not disclose his employment with a company known to the Grand
Jury or earnings paid to him by a company known to the Grand Jury Based on defendant SCOTT
CHRISTIE’s materially false representations, WorkForce West Virginia authorized defendant

SCOTT CHRISTIE to receive and he did receive UC benefits that he was not entitled to receive.
Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 5 of6 PagelD #: 5

19. On or about February 7, 2021, defendant SCOTT CHRISTIE again used the
WorkForce West Virginia website to file for Unemployment Compensation benefits and again
claimed “lack of work” as his reason for unemployment. In response to his claim, Defendant
SCOTT CHRISTIE was mailed a debit card from Key Bank on or about February 14, 2021, that
was loaded with weekly UC benefit funds, subject to defendant SCOTT CHRISTIE’s continued
qualification.

20. Employment and wage records maintained by a company known to the Grand Jury
indicate that defendant SCOTT CHRISTIE’s claim was again initially valid when made on
February 7, 2021, but that he returned to work at a company known to the Grand Jury on or about
February 27, 2021, and that he continued to be employed by a company known to the Grand Jury
until at least August 14, 2021. Between February 27, 2021, and August 14, 2021, defendant
SCOTT CHRISTIE submitted twenty-five (25) BWE certifications where he did not disclose his
employment with a company known to the Grand Jury or earnings paid to him by a company
known to the Grand Jury Based on defendant SCOTT CHRISTIE’s materially false
representations, WorkForce West Virginia authorized defendant SCOTT CHRISTIE to receive
and he did receive UC benefits that he was not entitled to receive.

21. In furtherance of the scheme, defendant SCOTT CHRISTIE submitted fraudulent
weekly certifications to WorkForce West Virginia, falsely stating that he was unemployed due to
the COVID-19 pandemic; that he had not received any wages or income; that he had not returned
to work full time; and that he had not worked any hours for the week in question, when in fact, he
was employed and earning wages.

22. As a result of these fraudulent statements, defendant SCOTT CHRISTIE caused

WorkForce West Virginia to authorize approximately fifty-two deposits to defendant SCOTT
Case 3:24-cr-00107 Document1 Filed 07/09/24 Page 6 of 6 PagelD #: 6

CHRISTIE’S debit cards issued by KeyBank, totaling $34,801.00, on behalf of WorkForce West
Virginia and the United States Department of Labor.

Theft of Government Money

23. From approximately February 10, 2020, through at least August 22, 2020, and from
approximately February 7, 2021, through at least August 14, 2021, at or near Leon, Mason County,
West Virginia, within the Southern District of West Virginia, and elsewhere, defendant SCOTT
CHRISTIE, knowingly and willfully stole, purloined, and converted to his own use money in an
amount greater than $1,000.00 from the Department of Labor, a department of the United States,
namely approximately $34,801.00 that was transferred to him in 52 transactions by Key Bank to a
debit card provided to him for his use by Key Bank at the direction of WorkForce West Virginia
and the United States Department of Labor, with the intent to deprive the United States Department
of Labor and WorkForce West Virginia of the use and benefit of that money and defendant SCOTT
CHRISTIE did so, knowing that he was not entitled to receive those funds.

In violation of Title 18, United States Code, Section 641.

WILLIA | . THOMPSON
United S Attorney

J. PARKER BAZZLE/II Jv
Assistant United States Attorney


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