Indictment — United States v. Jodi Headley, Northern District of West Virginia (Document 1)

Summary

A grand jury Indictment in United States v. Jodi Headley, Case 5:22-cr-00053-JPB-JPM, in the United States District Court for the Northern District of West Virginia, filed December 6, 2022. Count One charges mail fraud under Title 18, United States Code, Section 1341 in connection with the CARES Act Pandemic Unemployment Assistance (PUA) program administered by WorkForce West Virginia. It alleges that Headley, employed by Hancock County Schools, falsely stated in an application and weekly certifications that she was unemployed due to the COVID-19 pandemic and received no wages, intending to obtain approximately $20,979.00. The mailing charged is a debit card containing PUA funds sent on or about July 21, 2020. A forfeiture allegation seeks a money judgment of at least $20,979.00.

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       Case 5:22-cr-00053-JPB-JPM Document 1 Filed 12/06/22 Page 1 of 4 PageID #: 1


                         UNITED STATES DISTRICT COURT FOR THE                            PILED
                          NORTHERN DISTRICT OF WEST VIRGINIA
                                                                                       DEC 6 2022
  UNITED STATES OF AMERICA                                                           DISTRICT COu
                                                                                    WHE~jj~~ WV


  v.                                                Criminal No.      5:22-CR ~3

  JODI HEADLEY,
                               Defendant.           Violations:       18 U.S.C. 1341


                                          INDICTMENT

         The Grand Jury charges that:

                                            INTRODUCTION

         1.     On March 27, 2020, the Coronavirus Aid, Relief and Economic Security Act (CARES

Act) was signed into law. The CARES Act created the Pandemic Unemployment Assistance (PUA)

program, which provides unemployment benefits to individuals not eligible for regular unemployment

compensation or extended unemployment benefits.

         2.     The PUA program is administered by the State of West Virginia, but is funded by the

federal government.

         3.     In the State of West Virginia, WorkForce West Virginia is the agency that administers

the PUA program, on behalf of the United States Department of Labor, which is responsible for

overseeing the PUA program.

         4.     An applicant is only eligible to receive weekly PUA benefits if they are unemployed for

reasons related to the COVID- 19 pandemic. The applicant must first make a claim through the website,

and must enter personal identification information and answer a series of questions that enable

WorkForce West Virginia to determine the applicant’s eligibility and payment amount.

         5.     Each week, the applicant is instructed to report any work, i.e., any activity for which

payment is received, including full-time, part-time, or temporary work. At the end of each certification,

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    Case 5:22-cr-00053-JPB-JPM Document 1 Filed 12/06/22 Page 2 of 4 PageID #: 2


the applicant must check to acknowledge “I certify under penalty of perjury that the statements made in

connection with this claim are true to the best of my knowledge and belief’ and “I understand that I am

required to report any and all gross wages or income from any source every week that I claim

unemployment benefits regardless of the amount.”

                                             COUNT ONE

                                              (Mail Fraud)

       6.      Paragraphs 1 through 5 are hereby realleged as if fully set forth herein.

       7.      At all times relevant to this indictment, defendant JODI HEADLEY, was employed by

Hancock County Schools, in Hancock County, West Virginia. Starting no later than July 12, 2020, JODI

HEADLEY, devised a scheme and artifice to defraud and to obtain money from the United States

through which she intended to obtain approximately $20,979.00 by means of false and fraudulent

pretenses, representations, and promises.

       8.      It was part of the scheme that JODI HEADLEY submitted an application to WorkForce

West Virginia, requesting CARES Act unemployment funds distributed by the PUA program.

       9.      It was a further part of the scheme that JODI HEADLEY falsely stated on her application

to WorkForce West Virginia that she was unemployed due to the COVID-19 Pandemic.

       10.     It was a further part of the scheme that JODI HEADLEY submitted weekly certifications

to WorkForce West Virginia, falsely stating that she was unemployed due to the COVID-19 pandemic;

that she did not receive any wages or income, that she had not returned to work full time and that she

did not work any hours that week.

       11.     It was further part of the scheme that JODI HEADLEY misrepresented and concealed

material facts on her initial application and weekly certifications to WorkForce West Virginia about her

income from her employment at Hancock County Schools.

       12.     On or about July 21, 2020, in Hancock County, in the Northern District of West Virginia,

and elsewhere, for the purpose of executing such scheme and artifice, JODI HEADLEY, did knowingly
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    Case 5:22-cr-00053-JPB-JPM Document 1 Filed 12/06/22 Page 3 of 4 PageID #: 3


cause to be delivered by mail, according to the direction thereon, a matter and thing, that is a debit card

containing PUA funds, sent to her by KeyBank National Association, on behalf of WorkForce West

Virginia and the United States Department of Labor.

       In violation of Title 18, United States Code, Section 1341.




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                                     FORFEITURE ALLEGATION

                                                  Mail Fraud

        1.       Pursuant to Title 28, United States Code, Sections 2461(c), Title 18 United States Code,

Sections 981(a)(1)(C), 1956(c)(7)(A), and 1961(1) and Title 21, United States Code, Section 853, the

government will seek the forfeiture of property as part of the sentence imposed in this case, that is, the

forfeiture of any property, real or personal, which constitutes or is derived from proceeds traceable to a

violation of Title 18, United States Code, Section 1343, or a conspiracy to violate such offense, including

a money judgment in the amount at least $20,979.00

        2.      Pursuant to Title 28, United States Code, Section 2461(c), the government will seek

forfeiture of substitute property up to the value of property subject to direct forfeiture that is not available

for forfeiture on account of any act or omission contemplated by Title 21, United States Code, Section

853(p)(l).



                                                           A true bill,

                                                           /5/
                                                           Foreperson

/5/
WILLIAM IHLENFELD
United States Attorney



Jennifer T. Conklin
Assistant U.S. Attorney




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