Government’s Sentencing Memorandum, United States v. Shamiese Wright (S.D. W. Va., October 15, 2025)

Summary

The government's sentencing memorandum in United States v. Shamiese Wright, Criminal No. 2:24-CR-00192-2, in the U.S. District Court for the Southern District of West Virginia, filed October 15, 2025 as Document 404. Signed by Assistant United States Attorney Jonathan T. Storage, it addresses the factors in 18 U.S.C. § 3553(a). The memorandum states that in the spring of 2021 Wright aided and abetted another person in obtaining a PPP loan in her name on a false claim of $75,000 in 2020 gross income, that she received a $15,625 deposit, and that she paid $3,000 through Cash App. It gives the applicable Guidelines range as 0-6 months and states that the government has no reason to believe she will commit a similar offense again. Citing an interest in avoiding sentencing disparities, the government recommends a sentence of probation.

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Cite this document

“Government’s Sentencing Memorandum, United States v. Shamiese Wright (S.D. W. Va., October 15, 2025).” Original at ecf.wvsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-united-states-v-shamiese-wright-dkt-404-s-d-w-va-519a682f3e/, SHA-256 dbc7d22f8d6435f8e25cb9c111657befaa19626f440d0e7d1d0abbeb2269fe30.

Full text

Case 2:24-cr-00192     Document 404    Filed 10/15/25   Page 1 of 5 PageID #: 2694



                        UNITED STATES DISTRICT COURT
                     SOUTHERN DISTRICT OF WEST VIRGINIA
                                 CHARLESTON


UNITED STATES OF AMERICA


v.                                             CRIMINAL NO. 2:24-CR-00192-2


SHAMIESE WRIGHT


                     GOVERNMENT’S SENTENCING MEMORANDUM

      Comes now the United States of America,                  by Jonathan T.

Storage,   Assistant      United      States    Attorney    for   the   Southern

District of West Virginia and submits this Sentencing Memorandum

in aid of sentencing.

 I.   SENTENCING FACTORS

      The United States offers the following analysis relating to

the application of the sentencing factors enumerated in 18 U.S.C.

§ 3553(a). As discussed below, the government requests that the

Court impose a sentence of probation.

      A. History and Characteristics of the Offender

      The defendant is 32 years old and was born in Trenton, New

Jersey. The defendant described a tumultuous childhood, including

foster care placements during adolescence and her early teen years.

She noted her mother was a prostitute when she was involved with

the defendant’s father. Additionally, her mother suffered from
Case 2:24-cr-00192    Document 404    Filed 10/15/25    Page 2 of 5 PageID #: 2695



drug    addiction,    including      crack   cocaine     abuse.    She    has   no

relationship with her father.

       The defendant is single and had two twin girls, whose father

does not financially support them.

       She was expelled from high school, but she subsequently earned

her GED.

       She has a history of drug and alcohol abuse, including, at

times, drinking liquor and ingesting cocaine daily.

       B. Nature and Circumstances of the Offense

       During the spring of 2021, the defendant aided and abetted

Kisha Sutton to obtain a fraudulent Paycheck Protection Program

(“PPP”)      loan    through   a     federal    COVID-19       relief     program

administered by the U.S. Small Business Administration.

       The   defendant   supplied     her    personal    information      to    her

sister, who then passed it on to Kisha Sutton. At the time, Kisha

Sutton resided in New Jersey. Kisha Sutton created a materially

false PPP loan application in the defendant’s name and provided

false information and documentation to the lender. Specifically,

Kisha Sutton represented that the defendant was self-employed as

a “beautician” who had earned $75,000 in gross income in tax year

2020. Kisha Sutton backed up this claim by falsifying an IRS Form

1040-Schedue C in the defendant’s name.



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Case 2:24-cr-00192   Document 404   Filed 10/15/25   Page 3 of 5 PageID #: 2696



       The loan was approved, and the defendant received a $15,625

direct deposit into his bank account. As payment for her services,

the defendant sent three payments to Kisha Sutton through Cash

App, which totaled $3,000.

        C. Seriousness   of    Offense,    Deterrence,       and    Community
           Protection

       The defendant and Kisha Sutton took advantage of a national

emergency to enrich themselves. In doing so, they defrauded a

financial institution and took steps to conceal their actions.

       The government has no reason to believe that the defendant

will ever commit a similar offense again, and the defendant is not

a danger to the public.

       D. Sentencing Options

      The applicable Guidelines range in this case is 0-6 months.

Based on the facts and circumstances of the case, as well as the

government’s    interest in avoiding sentencing disparities, the

government recommends a sentence of probation.

II.    CONCLUSION

       The government submits that a sentence of probation would be

sufficient but not greater than necessary to meet the purposes of

sentencing.




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Case 2:24-cr-00192   Document 404   Filed 10/15/25   Page 4 of 5 PageID #: 2697




                                    Respectfully submitted,

                                    MOORE CAPITO
                                    United States Attorney
                             By:
                                    s/Jonathan T. Storage
                                    JONATHAN T. STORAGE
                                    Assistant United States Attorney
                                    WV State Bar No. 12279
                                    300 Virginia Street, East
                                    Room 4000
                                    Charleston, WV 25301
                                    Telephone: 304-345-2200
                                    Fax: 304-347-5104
                                    E-mail: Jonathan.Storage@usdoj.gov




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Case 2:24-cr-00192   Document 404   Filed 10/15/25   Page 5 of 5 PageID #: 2698



                         CERTIFICATE OF SERVICE

     It   is   hereby   certified   that   the   foregoing     “GOVERNMENT’S

SENTENCING MEMORANDUM” has been electronically filed and service

has been made on opposing counsel by virtue of electronic mail

this the 15th day of October, 2025, to:



                 Michelle R. Fox, Esq.
                 LAW OFFICES OF MICHELLE ROMAN FOX
                 3359 Teays Valley Road
                 Hurricane, WV 25526
                 Email: michellefox@smithlawpllc.net


                                    s/Jonathan T. Storage
                                    JONATHAN T. STORAGE
                                    Assistant United States Attorney
                                    WV State Bar No. 12279
                                    300 Virginia Street, East
                                    Room 4000
                                    Charleston, WV 25301
                                    Telephone: 304-345-2200
                                    Fax: 304-347-5104
                                    E-mail: Jonathan.Storage@usdoj.gov




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File and source

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SHA-256: dbc7d22f8d6435f8e25cb9c111657befaa19626f440d0e7d1d0abbeb2269fe30
Our copy: 404-sentencing-memorandum-by-united-states.pdf
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