Sentencing Memorandum of Defendant, United States v. Shamiese Wright (S.D. W. Va., October 15, 2025)

Summary

The defendant's sentencing memorandum in United States v. Shamiese Wright, Criminal No. 2:24-CR-00192, in the U.S. District Court for the Southern District of West Virginia, filed October 15, 2025 as Document 403 by counsel Michelle Roman Fox. It states that Wright pled guilty on July 14, 2025 to aiding and abetting laundering of monetary instruments under 18 U.S.C. § 1956(a)(1)(B) and agreed to restitution of up to $18,736.73. The memorandum accepts the probation officer's total offense level of 8 and Guideline range of 0-6 months, and states that as a Class C felony the offense is eligible for probation. It argues that three other defendants in the case received time served and 36 to 42 months of supervised release. Wright asks for a sentence of probation of 36 months, with sentencing set for October 29, 2025.

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 Case 2:24-cr-00192       Document 403        Filed 10/15/25      Page 1 of 6 PageID #: 2688




                       IN THE UNITED STATES DISTRICT COURT
                   FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
                                  At CHARLESTON


UNITED STATES OF AMERICA


v.                                                  Criminal No.: 2:24-CR-00192

SHAMIESE WRIGHT




                    SENTENCING MEMORANDUM OF DEFENDANT
                             SHAMIESE WRITGHT

       Comes Now, the Defendant Shamiese Wright, by and through her counsel Michelle

Roman Fox and hereby files this Sentencing Memorandum for consideration by this Honorable

Court in imposing its sentence on the Defendant. Sentencing is set for October 29, 2025, at

11:00 am.

       I.      OFFENSE CONDUCT:

       On July 14, 2025, Wright plead guilty to Aiding and Abetting Laundering of Monetary

Instruments in violation of 18 U.S.C. § 1956(a)(1)(B). Ms. Wright has acknowledged

responsibility for her actions and has expressed remorse.   She has also agreed to pay restitution

in the amount of up to $18,736.73.

       II.     GUIDELINE CALCULATIONS:

       The Probation Officer correctly calculated Ms. Wright’s total offense level as an 8, with a

recommended Guideline range of 0-6 months incarceration. In addition, Ms. Wright had 0

criminal history points. Ms. Wright has no objection to the Guideline calculations.

       III.    18 USC §3553 FACTORS
 Case 2:24-cr-00192        Document 403        Filed 10/15/25      Page 2 of 6 PageID #: 2689




       The Supreme Court’s decision in United States v. Booker, 543 U.S. 220 (2005), and the

Fourth Circuit’s ruling in United States v. Hughes, 401 F.3d 540 (4th Cir. 2005), require courts

to consider not only the recommended guideline range, but also the sentencing factors set forth in

18 U.S.C. § 3553(a), in determining the appropriate sentence for a particular defendant. The

overriding principle and mandate of Section 3553(a) requires district courts to impose a sentence

“sufficient, but not greater than necessary,” to comply with the four purposes of sentencing set

forth in Section 3553(a)(2). The sufficient-but-not-greater-than-necessary requirement is an

independent limit on the sentence in that the sentence must not be greater than necessary to

achieve the sentencing goals of § 3553.   In determining the appropriate sentence of “sufficient

but not greater than necessary” to comply with the § 3553(a)(2), the court must consider several

factors which are: (1) the nature and circumstances of the offense and the history and

characteristics of the defendant; (2) the need for the sentence imposed; (3) the kinds of sentence

available; (4) the kinds of sentences available under the advisory guideline range of the United

States Sentencing Guidelines; (5) any pertinent policy statements issued in the Guidelines; (6)

the need to avoid unwarranted sentencing disparity; and (7) the need to provide restitution to any

victim of the offense. 18 U.S.C. § 3553(a)(1-7).    No factor is given greater weight than any

other factor. The Defendant will address those factors which overwhelmingly support a sentence

of probation, with zero months incarceration, based upon the unique circumstances of Shamiese

Wright.

       A. The Nature and Circumstances of the Offense:

       Shamiese Wright, with the assistance provided by Lydia Spencer and Kisha Sutton,

applied for and obtained a PPP loan when she knew she was not eligible. In exchange for her

assistance in completing and submitting the forms, Shamiese Wright paid Kisha Sutton $3000,
 Case 2:24-cr-00192        Document 403        Filed 10/15/25      Page 3 of 6 PageID #: 2690




disguised as personal payments, in $1000 increments. While unequivocally acknowledging her

wrongdoing, Shamiese Wright wants this Court to know she was “in a very bad place” when she

committed this crime, one that was out of character for her. She was dealing with the infidelity

of her husband, severe depression and anxiety, and began hanging out with the wrong people and

turned to abusing alcohol and cocaine. She is remorsefully sorry for her actions. Importantly,

before her arrest in this case, she recognized she needed to change as her actions were affecting

not only her but her children, for whom she had sole custody and responsibility. She has now

fully changed her life, and has taken responsibility for her crime, by pleading guilty and agreeing

to restitution. Thus, the Court should consider “the circumstances” of her life that Shamiese was

dealing with when she committed this crime. Prior to her involvement in this case, Shamiese had

no criminal convictions. She lived her life, working and as a law-abiding citizen, raising her two

children.

       B. History and Characteristics of the Defendant.
       As fully set forth in the PSR ⁋ 40, Shamiese Wright had a sad and tough childhood.

Despite her efforts to have relationship with her biological father, he rejected her and refused to

form any relationship with her. Her mother, instead of proving a loving home for her, was

engaged in prostitution and drugs. This left Shamiese and her siblings to fend for themselves at

a young age and resulted in Shamiese being in and out of foster care.

       As an adult, Shamiese was physically and mentally abused by the father of her daughters.

She then thought she found a good relationship with her husband, only to have him engage in an

extramarital affair. PSR ⁋41-42.

       Despite all of these difficulties, Shamiese has persevered. She is a loving and caring

mother to her thirteen-year-old twin daughters.    She is their only parent, and they solely live

with her and rely upon her for all emotional and financial support and guidance. She is the one
 Case 2:24-cr-00192         Document 403        Filed 10/15/25       Page 4 of 6 PageID #: 2691




who makes sure they have food, a place to live, supplies for school, as well as making sure they

get to school and behave appropriately, which is sometimes difficult during these teenage years.

Their father has never provided any support for them and has never been a part of their lives.

       In addition, to providing a loving and supportive home to her daughters, Shamiese works

as a home health aid and hopes to go to nursing school. She also provides care for her ill

mother.

       C. The Need for the Sentence Imposed:
       Shamiese Wright understands she committed a crime and unlawfully applied for and

received loan funds to which she was not entitled to. She knows she must be punished.

However, given her significant family obligations to her twin daughters, as she is their only

parent and only support, the sentence imposed in this case should be probation. This sentence

will require Shamiese to follow stringent conditions as well as abide by all laws, but will at the

same time, not utterly upend the lives of her children. In addition, Shamiese Wright has been on

unsupervised release for almost a year since her arrest in this case and has not had any issues on

pretrial release. She will also be able to work to pay her restitution agreed to in this case.

       D. Kinds of Sentences Available and Policy Statements

       Since Shamiese Wright’s offense of conviction is a Class C felony, she is eligible for a

sentence of probation in lieu of incarceration. In addition, her recommended Guideline range is

in Zone A, and she is a Zero-point offender. Thus, pursuant to the advisory notes set forth in

USSG §5C1.1, advisory note 10, a sentence other than incarceration is advised and appropriate.

       E. The Need for Unwarranted Sentence Disparities:
 Case 2:24-cr-00192        Document 403        Filed 10/15/25      Page 5 of 6 PageID #: 2692




       The three other defendants sentenced in this case, all of which are similarly situated to

Shamiese Wright, received a sentence of time served and 36 to 42 months of supervised release.

None of these co-defendants received a sentence of incarceration. Thus, Shamiese Wright, in

order to avoid an unwarranted sentencing disparity, should likewise receive a non-custodial

sentence. Since her offense of conviction is a Class C felony, probation is appropriate.

       IV.     CONCLUSION

       Based upon the factors set forth above, Shamiese Wright requests this Court impose a

sentence of probation of 36 months. This sentence will promote justice, will be supportive of

Shamiese Wright’s parental responsibilities to her children, and is “sufficient but not greater than

necessary” to achieve the sentencing goals of 18 U.S.C. §3553.

                                                      Respectfully Submitted:

                                                      Shamiese Wright

                                                           BY COUNSEL

                                                      /s/ Michelle Roman Fox
                                                      Michelle Roman Fox
                                                      W.Va. Bar No. 5753
                                                      3359 Teays Valley Road
                                                      Hurricane, West Virginia 25526
                                                      (304) 552-2579 (telephone)
                                                      michellefox@smithlawpllc.net
                                                      mrfoxlaw@suddenlink.net
 Case 2:24-cr-00192        Document 403      Filed 10/15/25       Page 6 of 6 PageID #: 2693




                  IN THE UNITED STATES DISTRICT COURT FOR THE
                      SOUTHERN DISTRICT OF WEST VIRGINIA

                                 CHARLESTON DIVISION

United States of America


v.                                               Criminal Action NO. 2:24-00192


Shamiese Wright


                                CERTIFICATE OF SERVICE

       I, Michelle Roman Fox, counsel for the Defendant, Shamiese Wright certify on this 15th
day of October 2025, I served by CM/ECF filing the following DEFENDANT SHAMIESE
WRIGHTS’ SENTENCING MEMORANDUM upon counsel for the United States of
America.

                                    Jonathon Storage, Esq.
                               Assistant United States Attorney
                                   300 Virginia Street East
                                         Room 4000
                               Charleston, West Virginia 25301



                                                   Shamiese Wright

                                                        BY COUNSEL

                                                   /s/ Michelle Roman Fox
                                                   Michelle Roman Fox
                                                   W.Va. Bar No. 5753
                                                   3359 Teays Valley Road
                                                   Hurricane, West Virginia 25526
                                                   (304) 552-2579 (telephone)
                                                   michellefox@smithlawpllc.net
                                                   mrfoxlaw@suddenlink.net


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