Position Re: Sentencing; Exhibits — No. 2:21-cr-00580 (Dkt. 62, C.D. Cal.)
Summary
A position paper on sentencing with exhibits, Abdul-Malik McClain's Position Re: Sentencing; Exhibits, filed January 16, 2026 as Document 62 (40 pages) in United States v. Abdul-Malik McClain, Case No. 2:21-cr-00580-ODW, in the U.S. District Court for the Central District of California, assigned to Hon. Otis D. Wright, with sentencing set for 1/20/2026 at 11:00 a.m. Defense counsel Justin A. Palmer submits a memorandum in support of a sentence of 3 years of supervised release, citing the defendant's lack of criminal history and his family and community support. The memorandum discusses the advisory nature of the Sentencing Guidelines under United States v. Booker, and the exhibits include letters of support.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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“Position Re: Sentencing; Exhibits — No. 2:21-cr-00580 (Dkt. 62, C.D. Cal.).”
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Case 2:21-cr-00580-ODW Document 62 Filed 01/16/26 Page 1 of 40 Page ID #:251
1 Justin A. Palmer (SBN. 270857)
FILER | PALMER, LLP
2 8901 South La Cienega Boulevard, Suite 202
3
Inglewood, CA 90301
Telephone: (310) 658-8935
4 Facsimile: (562) 394-0504
Email: justin@filerpalmer.com
5
6
Counsel for Defendant,
ABDUL MALIK MCCLAIN
7
8 IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA –
9
10
UNITED STATES OF AMERICA, Case No. 2:21-cr-00580-ODW
[Assigned to Hon. Otis D. Wright]
11 Plaintiff,
ABDUL- MALIK MCCLAIN’S
FILER|PALMER, LLP
12 vs.
249 East Ocean Boulevard, Suite 501
POSITION RE: SENTENCING;
13 ABDUL-MALIK MCCLAIN EXHIBITS
Long Beach, CA 90802
14
Defendant. Sentencing Date: 1/20/2026
15 Time: 11:00 a.m.
Telephone (562) 304-5200 16
17
18 By and through his counsel of record, Justin A. Palmer, Abdul-Malik
19 McClain submits his position regarding sentencing. This position is based on the
20 files and records in this matter, the attached exhibits, and any further argument this
21 Court might require.
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28 [2026.01.16] Sentencing Position (final).docx 1
ABDUL- MALIK MCCLAIN’S POSITION RE: SENTENCING; EXHIBITS
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1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. INTRODUCTION & SENTENCING POST-BOOKER
3 Given the totality of the circumstances, including the factors under Federal
4 Rule of Criminal Procedure 11(c)(1)(B) and the history and characteristics of the
5 defendant as detailed below, Mr. Abdul-Malik McClain submits this memorandum
6 in support of a sentence of 3 years of supervised release. This sentence is sufficient
7 but not greater than necessary in light of Mr. McClain’s lack of criminal history and
8 his strong family and community support that provide a foundation for successful
9 rehabilitation.
10 The Sentencing Guidelines are not mandatory and a district court may not
11 presume that the Guidelines range is reasonable. See United States v. Booker, 543
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12 U.S. 220 (2005); Gall v. United States, 552 U.S. 38, 49-50 (2007). The Guidelines
13 are entitled to no more weight than any of the other 18 U.S.C. § 3553(a) sentencing
Long Beach, CA 90802
14 factors. Notably, Congressionally-directed guidelines are just as advisory as any
other guideline and therefore equally subject to policy-based variances.
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16 In Vazquez v. United States, 130 S. Ct. 1135 (2010), the Supreme Court
17 remanded for reconsideration in light of then-Solicitor General Kagan’s position that
18 “all guidelines,” including Congressionally-directed guidelines, “are advisory, and
19 the very essence of an advisory guideline is that a sentencing court may, subject to
20 appellate review for reasonableness, disagree with the guideline in imposing
21 [sentence] under Section 3553(a).” U.S. Br. at 11, Vazquez v. United States, No. 09-
22 5370 (Nov. 2009). As the Sixth Circuit has previously recognized, “all of the
23 sentencing guidelines are advisory,” including those directed by Congress. United
24 States v. Michael, 576 F.3d 323, 327 (6th Cir. 2009) (emphasis in original).
25 Congressional directives “tell the Sentencing Commission, not the courts, what to
26
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1 do,” and “a directive that the Commission specify a particular Guidelines range is
2 not a mandate that sentencing courts stay within it. Id. at 328.1
3 Ultimately, the Court must fashion a sentence that is appropriate, taking into
4 account all of the section 3553(a) factors. Gall, 552 U.S. at 49-50. Under section
5 3553(a), a sentence should be sufficient, but not greater than necessary, to achieve
6 the goals of sentencing. See also Kimbrough v. United States, 552 U.S. 85, 101
7 (2007). Through this directive of parsimony, Congress embedded in federal
8 sentencing legislation the moral imperative to impose on any individual the least
9 amount of suffering demanded by the general welfare. Consideration of the advisory
10 Guidelines range, while required, is subordinate to the overarching Congressional
11 mandate that the punishment be no greater than necessary to achieve the objectives
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12 of sentencing. As such, the sentencing Court must impose a particularized sentence
13 minimally sufficient to accomplish the statutory purposes of sentencing.
Long Beach, CA 90802
14 II. THE INDIVIDUAL BEFORE THE COURT
Abdul Malik McClain is a 26 year old with no prior criminal history who now
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15
16 faces sentencing for his very first conviction. To understand how he came before the
17 Court, it is important to recognize both his lifelong dedication to his family and the
18 circumstances of fear and desperation that led to this offense. Mr. McClain has
19 always been a loving husband, father, and son, known for working hard to provide
20 for his family and for contributing positively to his community. Mr. McClain's
21 athletic scholarship provided pathway to higher education and professional
22
1
None of the Guidelines at issue in this case – the drug guideline, the gun guideline, and the fraud guideline – were
23 promulgated as a result of the Commission’s use of institutional expertise and, instead, were crafted with
congressional dictates and the opinions of law enforcement at the forefront. As such, each of the Guidelines is subject
24 to the policy disagreement and the variances outlined in Vazquez. See generally U.S.S.G. § 2D1.1 comment,
backg’d) (2021) (explaining that the drug guideline was crafted to be proportional levels established by statute);
25 United States Sentencing Commission, Firearms and Explosive Materials Working Group Report (Dec. 11,
28 1990) (noting the input of ATF in crafting the increases to the firearms guidelines); Jeffery S. Parker & Michael K.
26 Block, The Sentencing Commission, P.M. (Post- Mistretta): Sunshine or Sunset?, 27 AM. CRIM. L. REV. 289, 319
(1989) (explaining that increases in the fraud guideline reflected increased congressional attention to then- current
27 fraud and insider trading scandals).
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1 opportunity. When injury foreclosed this path, he faced specific financial pressures.
2 This context—loss of planned trajectory combined with family financial
3 obligations—explains (though does not excuse) his decision to exploit the EDD
4 vulnerability. He made a deeply regrettable choice that was motivated to benefit his
5 family, a role he assumed at a young age.
6 Mr. McClain was born on October 10, 1999 in Riverside, California to Abdul
7 Malik McClain and Shanrika McClain. At present, he does not have a relationship
8 with his father and is unsure where his father is residing or what he is doing. (PSR
9 ¶¶66-67). His parents separated when he was 10 years old and Mr. McClain never
10 had a stable home, primarily raised by his mother Shanrika McClain in Georgia.
11 Growing up, Mr. McClain felt that his father had abandoned him when his
FILER|PALMER, LLP
249 East Ocean Boulevard, Suite 501
12 parents separated. Mr. McClain’s central parental figure, Shanrika, raised four
13 children as a single parent, and the family relocated back to California when Mr.
Long Beach, CA 90802
14 McClain was 16 years old. However, Mr. McClain spoke with his father by
telephone during the high school years on days Mr. McClain had a football game.
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15
16 (PSR ¶¶74).
17 Mr. McClain assumed parental duties at a young age, and started taking care of
18 his younger brothers (Munir, Alaa, Mansur). By adolescence, Mr. McClain was
19 responsible for and served as the central parental figure for his younger siblings.
20 These relationships exemplify the fact that Mr. McClain’s life has always been shaped
21 by family ties and that his family grew to depend on him at a young age. Research
22 finds that early parentification is a series of role reversals where a child is placed in
23 the role of needing to care, either physically or psychologically, for a parent or
24 siblings. “Parentified children are usually exposed to issues that they cannot fully
25 comprehend (such as parental substance use or mental health issues), [and] may be
26 required to manage problems that feel scary or that are too complex for a child to
27
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1 manage.” Dr. Ahona Guha, The Parentified Child in Adulthood, Psychology Today,
2 October 24, 2022, available at https://www.psychologytoday.com/us/blog/prisons-
3 and-pathos/202107/the-parentified- child-in-adulthood. Moreover, “anxiety remains
4 a highly common feature of the experiences of parentified children.” Id.
5 Mr. McClain recalls having a difficult childhood, and sought refuge in playing
6 sports -- baseball, basketball and football growing up – and quickly excelled as an
7 athlete. He chose to play at the University of Southern California (USC) on an athletic
8 scholarship, but his relationship with his father strained when he suffered a knee
9 injury and could not play. After his injury, he attempted to continue his athletic career
10 and college studies at Jackson State University and Texas College. At Jackson State
11 University, he suffered two additional injuries and was unable to play. He could not
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249 East Ocean Boulevard, Suite 501
12 complete his studies at Texas College because of financial issues, and continued his
13 studies at Saddleback Community College. Mr. McClain estimates he has 15 credits
Long Beach, CA 90802
14 remaining before earning his college degree.
Family has always defined Mr.
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15
16 McClain. He is a dedicated father of three
17 sons: Adhan (age 3), Kyro (age 1) and Major
18 (age 8 months). He takes pride in raising his
19 children and is encouraging them to avoid the
20 mistakes he made. While on supervised
21 release, he has celebrated their milestones and
22 encouraged their ambitions, instilling in them
23 a sense of perseverance that reflects his own
24 upbringing. These family connections are the
25 heart of who Mr. McClain is, and they remain his greatest motivation to change course
26 and ensure that this mistake is never repeated.
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1
2 Mr. McClain’s devotion to family has always extended outward into his
3 community. He has coached youth sports, and has worked to provide clothing and
4 resources to the unhoused community near the University of California at Los
5 Angeles. USC Department of Public Safety Chief John Thomas describes Mr.
6 McClain as “the epitome of leadership, student excellence and community service.”
7 Mr. Charles Jordan observed that Mr. McClain’s “intentions have always been
8 rooted in the well-being of those around him, particularly his family.” These
9 qualities reveal the broader truth about Mr. McClain’s character: that he has always
10 sought to build, support, and uplift those around him. These ties, combined with his
11 deep family connections, create a strong foundation for accountability and
FILER|PALMER, LLP
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12 rehabilitation.
13 Yet even as he devoted himself to his family and community, Mr. McClain
Long Beach, CA 90802
14 has struggled with health and emotional challenges. As noted above, he suffered
from various athletic injuries to his meniscus and shoulder. In 2019, he underwent
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16 surgery to repair a torn meniscus, and underwent a second surgery in 2020 to repair
17 his shoulder. He continues to manage pain whenever the knee is strained. Last year,
18 he was involved in a trucking accident while delivering materials in Wisconsin.
19 Alongside these physical struggles, Mr. McClain has also faced significant
20 mental health challenges. He has long struggled with anxiety and depression,
21 conditions that were aggravated by financial strain of trying to provide for his
22 family during difficult times. Anxiety has often left him feeling overwhelmed and
23 restless, while depression has created periods of hopelessness that clouded his
24 judgment. Although Mr. McClain has attempted to manage these conditions on his
25 own, they have had a demonstrable impact on his decision-making and his ability to
26 cope with stress. These struggles do not define who he is, but they highlight the
27
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1 importance of reentry programming and continued support so that he can move
2 forward in a healthier and more stable way.
3 At 26 years old, Mr. McClain stands before the Court for the first time in his
4 life. His appearance here does not reflect a pattern of criminal behavior but rather
5 isolated mistakes made in response to acute financial pressure and poor judgment.
6 He has expressed deep remorse and shame for his actions, acknowledging that his
7 conduct risked his freedom, his future, and the well-being of the family he treasures.
8 Yet his devotion to his partner, his children, his mother, and his siblings has not
9 wavered. With their ongoing support, and with his own determination to honor the
10 values he was raised with, Mr. McClain is committed to rebuilding his life in a way
11 that honors the love and loyalty of those who continue to stand by him.
FILER|PALMER, LLP
249 East Ocean Boulevard, Suite 501
12 III. THE PRESENTENCING REPORT AND RECOMMENDATION
13 On August 12, 2024, the United States Probation Office (“USPO”) timely
Long Beach, CA 90802
14 disclosed the Recommendation Letter (“Rec. Ltr.”) and Presentence Report (“PSR”).
(Dkts. 54, 55.)
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16 A. Objections
17 The defense makes the following objection and clarification to the PSR:
18 1. Mr. McClain qualifies as a zero-point offender under U.S.S.G. §§4C1.1(a)
19 and (b).
20 Mr. McClain has no criminal history points and has never before been
21 convicted of a federal offense. The instant case marks his first time before this Court,
22 and the guideline’s two-level reduction is intended precisely for defendants like him,
23 who do not have a sustained criminal record. The Sentencing Commission has
24 emphasized that zero-point offenders present a significantly reduced risk of
25 recidivism compared to repeat offenders. Applying this reduction here properly
26
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1 reflects Mr. McClain’s background and reinforces that he is not someone with an
2 entrenched pattern of unlawful behavior.
3 The Sentencing Commission's 2024 research on zero-point offenders
4 demonstrates they are rearrested at rates of 26.8%, compared to 42.3% for one-point
5 offenders within the same criminal history category—the largest variance within any
6 single category. This data supports the Commission's determination that the two-level
7 reduction under §4C1.1 is appropriate and reflects empirical reality about defendants
8 like Mr. McClain
9 IV. SENTENCING CONSIDERATIONS
10 a. The Plea Agreement.
11 In exchange for Mr. McClain’s guilty plea and waiver of his trial and most
FILER|PALMER, LLP
249 East Ocean Boulevard, Suite 501
12 appellate rights, the parties have agreed to jointly recommend the following Base
13 Offense Level, Specific Offense Characteristics, Adjustments, and Departures (if
Long Beach, CA 90802
14 applicable):
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15 a. Base Offense Level ……………………….……………....…….7
16 b. Loss Greater than $550,000 and less than or equal to
17 1,500,000.0……………………………………………....…...+14
18 c. Use of means of ID to obtain means of ID…………….......….....+2
19 d. Leader/Organizer………………….………………………..……+4
20 e. Acceptance of Responsibility ……………………….….…..…..-3
21 In addition, the parties have further agreed that Mr. McClain and the
22 Government may request or recommend additional adjustments and departures under
23 the USSG and sentencing reductions under 18 U.S.C. section 3553.
24 In light of this agreement, Mr. McClain submits the following additional
25 information for the Court’s consideration.
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1 1. Mr. McClain accepted responsibility for his conduct at an early stage of
2 the proceedings. He entered a timely guilty plea, sparing the government and the
3 Court the time and resources that would have been required for trial. Beyond his plea,
4 he has consistently expressed genuine remorse for his actions and has acknowledged
5 the seriousness of his involvement. He has also demonstrated insight into the poor
6 decisions that led to this offense and has described this case as a turning point in his
7 life. Under U.S.S.G. §3E1.1, a three-level reduction is therefore appropriate,
8 reflecting his early plea, his cooperation, and his willingness to confront his mistakes
9 directly.
10 2. Mr. McClain qualifies as a zero-point offender under U.S.S.G.
11 §§4C1.1(a) and (b). He has no criminal history points and has never before been
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249 East Ocean Boulevard, Suite 501
12 convicted of a federal offense. The instant case marks his first time before this Court,
13 and the guideline’s two-level reduction is intended precisely for defendants like him,
Long Beach, CA 90802
14 who do not have a sustained criminal record. The Sentencing Commission has
emphasized that zero-point offenders present a significantly reduced risk of
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16 recidivism compared to repeat offenders. Applying this reduction here properly
17 reflects Mr. McClain’s background and reinforces that he is not someone with an
18 entrenched pattern of unlawful behavior.
19 b. Advisory Guideline Range
20 As indicated above, Mr. McClain starts at a Base Offense Level of 7 for mail
21 fraud under USSG §2B1.1(a)(2). The offense level is increased by 14 levels based on
22 the value of the loss funds pursuant to USSG §2B1.1(b)(1)(G), two levels because
23 means of ID were used in obtaining the funds under USSG §21.1(b)(1), and four
24 levels for Mr. McClain’s involvement in the crime. With these adjustments, Mr.
25 McClain’s subtotal is 27. From there, he receives a two-level reduction as a zero-point
26 offender under USSG §4C1.1, and a three-level reduction for acceptance of
27
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1 responsibility under USSG §3E1.1. Mr. McClain therefore ends with a total offense
2 level of 22. At 22, with a Criminal History Category of I, his advisory guideline range
3 is 41 to 51 months. See USSG, Sentencing Table and the Probation Officer’s
4 Presentence Investigation Report.
5 c. Factors Under Title 18, United States Code, Section 3553(a)
6 Under the Supreme Court’s decisions in United States v. Booker, 543 U.S.
7 220 (2005), Rita v. United States, 551 U.S. 338 (2007) and Gall v. United States,
8 552 U.S. 38 (2007), when imposing sentence on a criminal defendant the district
9 court must first correctly calculate the advisory sentencing guideline range and then
10 determine an appropriate sentence based on all of the factors set forth in 18 U.S.C.
11 Section 3553(a). See United States v. Carty, 520 F.3d 984, 991-992 (9th Cir. 2008).
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12 After consideration of these factors, the statute directs the court to impose a sentence
13 that is “sufficient, but not greater than necessary” to satisfy the purposes of
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14 sentencing set forth in subdivision (a)(2). The “parsimony provision” represents the
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15 overarching command of the statute. Kimbrough v. United States, 552 U.S. 85
16 (2007).
17 After determining the proper advisory Guideline range, the Court must
18 evaluate whether the sentence is substantively reasonable and comports with the
19 purposes of sentencing. Specifically, federal law requires that the Court consider
20 the following factors in imposing sentence:
21 (1) the nature and circumstances of the offense and the history and
22 characteristics of the defendant;
23 (2) the need for the sentence imposed –
24 a. to reflect the seriousness of the offense, to promote respect for the
25 law, and to provide just punishment for the offense;
b. to afford adequate deterrence to criminal conduct;
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c. to protect the public from further crimes of the defendant; and
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1 d. to provide the defendant with needed educational or vocational
2 training, medical care, or other correctional treatment in the most
3 effective manner;
See Title 18, United States Code, Section 3553(a).
4
Applying these factors, it appears that a variance under Section 3553(a),
5
although greater than the variance recommended by United States Probation, is
6
warranted in this case.
7
1. Nature and Circumstances of the Offense
8
Mr. McClain's history and characteristics are fully detailed in Section II,
9
above, and in the Presentence Investigation Report. The seriousness of this offense
10
is undisputed. However, the nature and circumstances of this offense occurred
11 during a period when the Employment Development Department system presented
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249 East Ocean Boulevard, Suite 501
12 unprecedented structural vulnerabilities. In 2020, when California was under
13 economic lockdown, the EDD faced massive volume spikes, minimal verification
Long Beach, CA 90802
14 protocols, and non-specialized federal enforcement posture regarding fraudulent
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15 claims. Simultaneously, my client faced acute financial pressure: his athletic
16 scholarship money had ended, he was ineligible for other types of relief and had
17 exhausted personal savings and obligations for his family.
18 Mr. McClain made the criminal choice to exploit the EDD system's
19 vulnerability during this window of opportunity. This was not a victimless
20 exploitation of a minor administrative program—it was federal fraud during a
21 national emergency. He deserves punishment; however, the distinction between
fraud perpetrated during the nascent federal enforcement period of 2020-2021 and
22
fraud committed in 2025, after three years of dedicated task forces and consistent
23
prosecution, informs the degree of that punishment under §3553(a). My client's
24
decision to commit fraud reflected the incentive structure that existed at that
25
moment—low perceived risk, immediate benefit, structural vulnerability. When the
26
federal government substantially altered that incentive structure through consistent
27
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1 enforcement, the rational calculus changed. Sentencing my client as though he acted
2 under the post-2022 enforcement environment would fail to account for the
3 temporal and structural context of his specific offense.
4 Also, while the sentencing guidelines recognize Mr. McClain’s role as an
5 organizer, the specific nature of that organization—the structure, duration, scale, and
sophistication of his leadership—differs materially from the archetypal conspiracy
6
leadership that enhancements of this kind are designed to address. This crime was
7
not committed by a criminal organization, and Mr. McClain’s role was not to design
8
a complex scheme, manage dozens of subordinates, or operate a transnational
9
criminal enterprise. Mr. McClain exercised no authority over others who received
10
these funds and had no power to exclude anyone from submitting an application for
11
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the funds. Courts regularly consider these distinctions when applying §3553(a)
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12
factors to determine an appropriate sentence within or below the guideline range.
13 Moreover, following his arrest, Mr. McClain significantly contributed to the
Long Beach, CA 90802
14 efficiency of the legal process by accepting a plea agreement, thereby saving the
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15 government time and resources. Additionally, he has demonstrated a clear
16 acceptance of responsibility for his actions and acknowledged the poor judgment
17 that led to his offense.
18 2. History and Characteristic of Mr. McClain
19 The history and characteristics of Mr. McClain are documented as set forth in
20 section II. Individual Before the Court, supra, and the Presentence Investigation
21 Report, and are incorporated herein by reference.
22 Mr. McClain is a 26 year old man with no prior criminal convictions who has
23 otherwise lived a law-abiding and productive life. He is a devoted partner, father,
24 brother, and friend, known for his loyalty to family and his commitment to his
25 community. His involvement in this offense was the result of financial strain and
26 coercion, not a reflection of who he has been for the majority of his life.
27
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1 Mr. McClain’s character is also reflected in the life he has led within his
2 community. He has consistently shown himself to be a compassionate and
3 dependable neighbor, including dedicating his time to coaching youth sports.
4 Friends and colleagues describe him as someone who could always be counted on to
5 step in and help, whether it was supporting a community project or offering
6 assistance to those in need. These years of positive contributions underscore that Mr.
7 McClain’s identity is not defined by this offense, but rather by his steady record of
8 generosity, reliability, and commitment to those around him.
9 Mr. McClain has acknowledged substance abuse during the period of this
10 offense. These conditions left him emotionally vulnerable and more susceptible to
11 poor decision-making. Although he has managed his symptoms as best he can, his
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12 mental health remains fragile and would benefit greatly from consistent treatment
13 and counseling.
Long Beach, CA 90802
14 Despite these hardships, Mr. McClain has expressed deep remorse for his
actions and will explain in more detail at sentencing. He has accepted responsibility
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15
16 at an early stage, sparing the government significant resources, and he has described
17 this case as a profound turning point in his life. He has reflected on the harm his
18 conduct has caused to his family and to himself, and he is committed to rebuilding
19 his life with honesty and stability.
20 Mr. McClain would benefit from participation in reentry and rehabilitative
21 programming through the Bureau of Prisons, including cognitive behavioral therapy,
22 mental health counseling, and vocational training. Mr. McClain’s history and
23 characteristics demonstrate that this offense is an aberration, not a pattern of
24 conduct. With appropriate treatment and supervision, he has the potential to return
25 to his role as a supportive partner, father, and son, and to continue being a valued
26 member of his community.
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1 a. Family support aids rehabilitation and lowers risk of recidivism.
2 In the case of U.S. v. Sayad, 589 F.3d 1110 (10th Cir. 2009) “where defendant
3 convicted of interstate delivery of 11 kilograms of cocaine and guidelines say 57
4 months, sentence of probation is reasonable in part because, unlike in most cases,
5 here strong family support which will aid rehabilitation.”
Beyond his own commitment to change, Mr. McClain possesses a powerful
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protective factor: strong and enduring family support. His family has remained
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steadfast throughout this process, offering both encouragement and accountability as
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he works to move forward. His children remain a source of profound motivation, as
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they depend on him for guidance, stability, and love. He remembers his father's
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absence and is determined to be more present in his children's lives than his own
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father was in his. These family connections, along with the support of his siblings
249 East Ocean Boulevard, Suite 501
12
who remain in Orange County, ensure that Mr. McClain will have a strong familial
13 network to return to. Mr. McClain's family support extends beyond emotional
Long Beach, CA 90802
14 encouragement. This network provides the accountability structure that research
Telephone (562) 304-5200
15 shows correlates with successful reentry. Unlike many federal defendants, Mr.
16 McClain does not face reentry into instability—he faces reentry into structure.
17 Additionally, Mr. McClain has long been a strong and reliable figure in his
18 community, and his neighbors and friends he once supported are now committed to
19 standing by him as he works to rebuild his life. The presence of this support system
20 provides the structure and accountability necessary for his successful reintegration
21 and strongly indicates that he is capable of remaining law-abiding in the future.
22 b. Prison Time More Significant for First Offender so Below Guideline
23 Sentence More Just
24 For a first-time offender such as Mr. McClain, a term of imprisonment carries
25 greater weight and deterrent value than it would for someone who has been
26 previously incarcerated. Federal courts have consistently recognized that the
27 experience of prison is uniquely significant for defendants with no prior record. The
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1 United States Sentencing Commission itself has acknowledged that imposing
2 lengthy terms on first-time offenders may create punishments “greater than
3 necessary” to achieve the goals of sentencing.
4 In United States v. Willis, 479 F. Supp. 2d 927 (E.D. Wis. 2007), the district
5 court emphasized that a below-guideline sentence was appropriate in a drug case
6 where the guidelines called for 120 months but the court imposed 60 months
7 instead. The court reasoned that the statutory minimum sentence already represented
8 a “substantial punishment” for a defendant who had never before been to jail or
9 prison and who did not engage in violence or dangerous behavior. The court found
10 that this shorter term was sufficient to deter the defendant and protect the public,
11 recognizing that the first experience of incarceration has a greater impact on a first
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12 offender than on a recidivist.
13 Similarly, in Mr. McClain’s case, even a relatively modest custodial sentence
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14 will be profoundly impactful. At 26 years old, Mr. McClain has never before been
incarcerated. A sentence of supervised release will not only punish and deter him
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16 but also send a clear message to others, without resorting to the unnecessarily severe
17 range recommended by the Guidelines. Just as the court in Willis recognized, the
18 reality of imprisonment for someone with no prior exposure to jail or prison is itself
19 a powerful sanction, making a below-guideline sentence more just and
20 proportionate.
21 3. The Need for the Sentence Imposed
22 The Court must also consider the need for the sentence imposed to reflect the
23 seriousness of the offense, promote respect for the law, provide just punishment,
24 afford adequate deterrence, protect the public, and provide Mr. McClain with the
25 necessary treatment, structure, and programming to support his successful reentry.
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1 A sentence of three years of supervised release with conditions for reentry
2 programming, satisfies each of these goals. Federal probation is a significant
3 sanction for a first-time offender who has never before been incarcerated, and it will
4 impress upon Mr. McClain the seriousness of his conduct. At the same time, such a
5 sentence avoids imposing punishment greater than necessary, consistent with section
6 3553(a)’s command that courts impose the least severe sentence sufficient to
7 achieve the goals of sentencing.
8 This sentence will also provide adequate deterrence. Mr. McClain is 26 years
9 old with no history of violence or prior convictions, and he has never before
10 experienced incarceration. Longer terms are not necessary to achieve deterrence,
11 particularly given Mr. McClain’s age, lack of criminal background, and
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12 demonstrated remorse.
13 Protecting the public is also a central consideration. Mr. McClain poses no
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14 risk of violence, and the record shows that his involvement was limited and
motivated by financial strain and threats, rather than a desire for ongoing criminal
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15
16 activity. With his age, strong family ties, and long history of positive contributions
17 to his community, Mr. McClain is extremely unlikely to reoffend. Supervision,
18 coupled with reentry programming, will ensure that the public remains protected
19 while supporting his rehabilitation.
20 Finally, the recommended sentence will allow Mr. McClain to access
21 programs that will address his needs and provide him with structure as he transitions
22 back into the community. Mr. McClain supports his three children, and his partner
23 does not work. Various exhibits that document Mr. McClain’s work history are
24 included and attached as exhibits to this Sentencing Position.
25 a. To Reflect the Seriousness of the Offense, Promote Respect for the
26 Law, and Provide Just Punishment
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1 Based on all of the circumstances, a sentence of supervised release adequately
2 reflects the nature of the offense. While the offense was serious, Mr. McClain's
3 personal financial gain was substantially less than the total loss amount, suggesting
4 his role was not as central as the loss figure might indicate. A sentence at this level
5 still sends a strong message that such conduct is unacceptable, while avoiding a
6 punishment that would overstate his culpability.
7 Similarly, such a sentence promotes respect for the law. Mr. McClain has
8 already been deeply impacted by his arrest, prosecution, and the weight of federal
9 sentencing. He has had painful and honest conversations with his partner and
10 siblings about the choices that led him here, and he has accepted the shame and
11 disappointment that his actions caused his family. He has expressed heartfelt
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12 remorse, acknowledging that his decision was misguided and damaging. He
13 understands now that such behavior not only endangered his own future but also
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14 betrayed the values of responsibility and integrity that he has long tried to instill in
his children and grandchildren.
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15
16 Supervised release also provides just punishment under the circumstances.
17 This is Mr. McClain’s first criminal conviction, and the experience of being
18 incarcerated, separated from his family, and facing federal sentencing has been
19 sobering and transformative. As a first-time offender, Mr. McClain's experience
20 with the criminal justice system has provided sobering perspective on the gravity of
21 his mistake. He has come to realize that continuing on this path would only cause
22 more pain and destruction, and instead, he is committed to rebuilding his life with
23 the stability and responsibility that his family and community have always known
24 him for.
25 Mr. McClain’s remorse is genuine. He accepts responsibility for his actions
26 without excuse, recognizing that he alone is accountable for the choices he made.
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1 His recognition of the harm caused and his proactive commitment to change
2 demonstrate that a sentence of supervised release is sufficient but not greater than
3 necessary to achieve this statutory goal.
4 b. To Afford Adequate Deterrence to Criminal Conduct
5 Supervised Release also adequately serves the statutory purpose of
6 deterrence. Mr. McClain has never before been convicted of a crime, and the
7 experience of being arrested, prosecuted, and held accountable in federal court has
8 already had a profound impact on him. At 26 years old, the prospect of incarceration
9 is especially daunting – both the separation from his young children and the inability
10 to provide for them financially are profoundly meaningful deterrents.
11 General deterrence is also served by such a sentence. It demonstrates that mail
FILER|PALMER, LLP
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12 fraud carries serious consequences. The public will understand that participation in
13 financial crimes tied to criminal conduct cannot be excused, while at the same time
Long Beach, CA 90802
14 recognizing that justice requires proportionality. A below-guideline sentence here
still communicates accountability and reinforces the seriousness of the offense.
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15
16 Importantly, Mr. McClain’s age, lack of prior convictions, and deep ties to
17 family and community make him highly unlikely to reoffend. The Sentencing
18 Commission has consistently recognized that first-time offenders like Mr. McClain
19 present a significantly reduced risk of recidivism. The deterrent value of a lengthy
20 prison term is minimal compared to the rehabilitative benefit of a sentence that
21 allows him to remain with his children and family, and continue contributing
22 positively to his community. A sentence of supervised release is therefore sufficient,
23 but not greater than necessary, to satisfy both personal and general deterrence under
24 § 3553(a)(2)(B).
25 c. To Protect the Public from Further Crimes of the Mr. McClain
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1 The Court must also consider whether a custodial sentence is necessary to
2 protect the public from future crimes by Mr. McClain. In this case, the risk of
3 recidivism is exceptionally low. As the Sentencing Commission has noted in
4 research on zero-point offenders, first-time offenders with Mr. McClain's
5 demographic profile and family structure present recidivism rates substantially
6 below the general federal offender population. Mr. McClain is 26 years old, with no
7 prior criminal convictions, and his life has been defined by family, community, and
8 hard work rather than criminal conduct. This offense represents an isolated lapse in
9 judgment, influenced by financial strain and external pressures, not a pattern of
10 ongoing unlawful behavior.
11 Mr. McClain has expressed sincere remorse and shame for his actions. He has
FILER|PALMER, LLP
249 East Ocean Boulevard, Suite 501
12 acknowledged the gravity of his mistake and has reflected deeply on the harm it has
13 caused his family and his own future. He has strong motivation to avoid any further
Long Beach, CA 90802
14 involvement in criminal activity, as his priority is to remain present for his partner,
children, and infant children. His family support system is extensive and committed,
Telephone (562) 304-5200
15
16 ensuring that he will have the accountability and structure necessary to succeed
17 upon release.
18 Moreover, the Sentencing Commission has recognized that defendants who
19 are first-time offenders, particularly those with strong community and family ties,
20 present a much lower risk of recidivism than repeat offenders. The public is best
21 protected not by imposing a lengthy custodial sentence on Mr. McClain, but by
22 allowing him to remain under supervised release conditions that will provide
23 monitoring, guidance, and structure. This sentence adequately strikes the appropriate
24 balance between accountability and protecting the public, without imposing a
25 punishment greater than necessary.
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1 d. To Provide Mr. McClain with Needed Educational or Vocational
2 Training, Medical Care, or Other Correctional Treatment in the
3 Most Effective Manner
4 Another purpose of sentencing is to ensure that the defendant receives the
5 medical care, mental health treatment, and structured support necessary for
6 rehabilitation. Mr. McClain has a history of marijuana abuse, and has participated in
7 this Court’s STAR program since 2024. His participation in the program confirms
8 the need for substance abuse training and education, and addressing these issues
9 through counseling and structured treatment will be far more effective in reducing
10 the risk of recidivism than a lengthy custodial term.
11 e. Summary and Request for Variance
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249 East Ocean Boulevard, Suite 501
12 In 2020-2021, the EDD system represented a systemic vulnerability that
13 individuals facing hardship could receive funds with relative ease. Mr. McClain
Long Beach, CA 90802
14 facing acute financial need during the economic lockdown, responded to the
Telephone (562) 304-5200
15 incentive structure of a vulnerable system: he perceived high probability of
16 approval, low detection risk, and immediate financial benefit. This is rational actor
17 analysis, not excuse—it explains the timing and nature of the offense, which informs
18 §3553(a) analysis.
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1
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3 Dated: January 16, 2026 Respectfully Submitted,
4 FILER | PALMER, LLP
5
6 By:
7 Justin A. Palmer
Counsel for Defendant,
8 ABDUL-MALIK MCCLAIN
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UNIVERSITY OF CALIFORNIA, LOS ANGELES UCLA
BERKELEY · DAVIS · IRVINE · LOS ANGELES · MERCED · RIVERSIDE · SAN DIEGO · SAN FRANCISCO SANTA BARBARA · SANTA CRUZ
POLICE DEPARTMENT
601 WESTWOOD PLAZA
BOX 951364
LOS ANGELES, CALIFORNIA 90095-1364
April 4, 2024
To Whom it Concerns:
I’m writing you in support of Mr. Abdul-Malik McClain. As the current Chief of Police for the UCLA
Police Department, and as the previous Chief of the University of Southern California Department of
Public Safety (where I served 16 years) and a law enforcement executive in the City of Los Angeles now
in my fourth decade of service, having also served with the Los Angeles Police Department (both as a
full time sworn officer for 21 years, and as a Level 1 Reserve officer for 17 years), I met Mr. McClain
quite a few years ago while I was serving at USC and he approached me with an idea of providing shoes
to some of the members of the large unhoused members of the community living around the university.
During my entire tenure serving at both universities, that stands as the only time a student on his/her own
initiative sought to collaborate with law enforcement to help the homeless living within the community. I
agreed to assist him and other student athletes that he’d elicited to help and we were not only to
successfully provide the donated shoes to members of the community, but, he launched several other
initiatives (clothing and food drives) to aid the less fortunate members of the community. Each event
were partnerships between our department and, students and community organizations.
He was and remains the epitome of leadership, student excellence and community service. Through him
I was also able to meet other members of his similarly community service-oriented members of his
family who like him, I continue to maintain contact with. He has my continued support and mentorship.
I have every confidence in the character, commitment to excellence and achievement of future positive
professional and personal goals of Mr. McClain. I appreciate and value his consistent dedication to
helping those around him, and those in need and, I thank you for allowing me the opportunity to express
my complete confidence and support of him and in his future endeavors. Should you need any additional
information, please do not hesitate to reach out to me personally.
Sincerely,
John Thomas
Chief of Police
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My name is Shanrika McClain, and I am writing to share the profound impact my son Abdul-Malik
McClain charges of mail fraud have had on me and our family. Abdul-Malik McClain, my oldest son of
four children, was born from a union blessed by God, then raised up as a young man in a single mom
household. He has always been a pillar of strength and faith for our family.
From a young age, Abdul-Malik exemplified the values of compassion, generosity, and community
service. He shared his blessings with his siblings, gave food and clothing to those in need, and
consistently achieved good grades as a student. His faith has always been strong, and he has embodied
the principles of our teachings by striving to care for family and friends. Whenever he encountered a
homeless person, he would not only provide them with food and clothing but also offer them a kind
conversation. His actions reflected a deep sense of empathy and responsibility.
I have watched my son grow from a baby to a dedicated student in elementary, middle, high school,
college, and then to a caring and responsible father of two sons. He has always taken his role as the
leader of our family seriously, positively impacting both us and our community. His efforts to support
disadvantaged individuals have been relentless, always driven by a desire to see everyone around him
thrive. Malik felt giving back to the homeless on Skid Row was his responsibility while attending
University of Southern California as a student-athlete. He would ride a bike or walk throughout the
community to help the homeless.
For the past four years, our family has been impacted emotionally, mentally, physically, socially, and
economically strained as we have grappled with Abdul-Malik’s legal battles. Knowing that he is fighting
for his freedom has felt like a parallel fight for our own freedom. We are deeply connected, and his
struggle reverberates through all aspects of our lives. The thought of my firstborn son potentially being
confined to a prison, which I perceive as a modern-day institution of slavery, haunts me daily.
I pray fervently for mercy and grace for Abdul-Malik. I ask for a second chance for him to be free and to
restore his life outside of prison walls. As a mother, my cry for his freedom is incomparable. Abdul-Malik
dreams of playing football in the National Football League, completing his college degree, raising his
children, and continuing to serve his community. At 24 years old, with his brain still developing, I beseech
the judicial system to consider restorative justice. Grant him the opportunity to make amends and to live
a life that benefits not only himself but also those he loves and serves.
This situation has been nothing short of horrific for our family. Abdul-Malik is an exceptional person and
student-athlete. He attended JSerra Catholic High School, where he earned the title of Athlete of the
Year and was a contender for the prestigious Dick Butkus Award. He was awarded over $3 million in
scholarships to attend Division I colleges and chose to study Communications at the University of
Southern California. Despite the high hopes and achievements, his current predicament marks a
significant fall from grace.
I implore the judicial system to grant Abdul-Malik another chance to rebuild his life, earn his respect as a
United States citizen, pay restitution, and fulfill his potential. Our family’s faith, love, and support for him
remain unwavering, and we believe in his ability to learn from this experience and emerge as a stronger,
wiser individual.
Sincerely,
Shanrika McClain (Mother)
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