Sentencing Memorandum, United States v. Crandall Speights (District of Delaware, September 12, 2025)

Summary

A defense sentencing memorandum in letter form, dated September 12, 2025 and addressed to Honorable Richard G. Andrews, in United States v. Crandall Speights, Criminal No. 23-00078-001(RGA), in the U.S. District Court for the District of Delaware, filed as Document 52. It states that on May 9, 2025 the defendant pleaded guilty to counts one, two, and four through ten, charging bank fraud, wire fraud, conspiracy to commit wire fraud and money laundering. It notes the Presentence Investigation Report's total offense level of 20, criminal history category VI and guideline range of 70 to 87 months. Counsel asks for a downward variance under 18 U.S.C. § 3553(a), citing the defendant's personal history, health, remorse and time in custody. Attached exhibits include a letter from the defendant and letters of support; the memorandum is from Stanley O. King.

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“Sentencing Memorandum, United States v. Crandall Speights (District of Delaware, September 12, 2025).” Original at ecf.ded.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sentencing-memorandum-usa-v-speights-dkt-52-46daa1bbbb/, SHA-256 a8dd433200e0c94dde5ac50792b5eb4d65d71c16eaa125f82f60e1bdce98bbed.

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Case 1:23-cr-00078-RGA Document 52 Filed 09/12/25 Page 1 of 32 PageID #: 175

September 12, 2025

Honorable Richard G. Andrews, U.S.D.J.
United States District Court
District of Delaware
J. Caleb Boggs Federal Building
844 King Street
Wilmington, Delaware 19801

Re: United States v. Crandall Speights
Criminal No. 23-00078-001(RGA)
Sentencing Memorandum

Dear Judge Andrews:

I represent the defendant, Crandall Speights with regard to the above-referenced matter.
On May 9, 2025, Mr. Speights pleaded guilty to counts one, two, and four through ten of his
indictment which charged him with bank fraud, wire fraud, conspiracy to commit wire fraud and
money laundering, in violation of 18 U.S.C. § 1334, 1343, 1349 and 1957.

Mr. Speights’ sentencing is scheduled for September 18, 2025, at 10:00 a.m. Please accept this
letter memorandum in lieu of a more formal sentencing memorandum.

FACTUAL BACKGROUND

Mr. Speights is 43 years old and was born in Mariana, Florida. But for the fact that he was born
on American soil in the twentieth century, his life has all the makings of a Greek tragedy. His
parents separated early in his life, and he was primarily raised by his single mother. At the age of
four, the tragedy began. He became the victim of sexual abuse. He was repeatedly sexually
assaulted by a male member of his family. This abuse continued for over a year. His mother wanted
to get him away from his abuser and create a better life for her family. She made the decision to
move. She took three of her children and left the state of Florida.
Case 1:23-cr-00078-RGA Document 52 Filed 09/12/25 Page 2 of 32 PageID #: 176

Honorable Richard G. Andrews, U.S.D.J.
September 12, 2025
Page 2

Before his eighteenth birthday, he had moved between five different states. He lived in the States
of Florida, Alabama, North Carolina, Ohio and Massachusetts. Because of this constant relocation,
he was unable to make and maintain friendships. His education was constantly disrupted and
negatively affected. It became difficult for him to become completely familiar with his
surroundings. This disruption and instability became a pattern in his life. Unfortunately, sexual
abuse also became a familiar pattern.

Around the age of eighteen he moved out on his own. He continued to struggle with the trauma of
his childhood. He refused to talk about the sexual abuse that he suffered at various times
throughout his childhood. His mother recognized that he needed help and tried to get him
counseling. It was too difficult for him to disclose the depths of his sexual abuse and trauma.
Therefore, the counseling was unsuccessful and ended. He joined a church and became a very
active member. He was hoping to find closure, a “father figure” and spiritual guidance. He knew
he needed help and believed he could find it in a church. Unbeknown to him at the time he joined
the church, his pastor and mentor was a sexual predator. Instead of finding the solace that he hoped
for, he was sexually victimized again. His pastor began a sexual affair with him that lasted several
years, all the while being his “spiritual mentor”. 1 He was confused, lonely and struggling with his
sexual identity.

It was important for Crandall to feel important. He sought out positive attention. He wanted to
look successful in the eyes of others. He wanted to be important, successful and needed. He wanted
the members of his church and others to look up to him and admire his generosity and kindness.
He wanted to display his success through his generosity and charity. In addition to his tithing, he
wanted to contribute to the church reaching its financial goals. He wanted to help other members
of his church that were in need. He wanted to help his pastor. He did all those things. However, to
create that lifestyle and facade, came with a cost. He became immersed in a life of deception and
fraud.

SENTENCING GUIDELINES ANALYSIS

The Presentence Investigation Report (“PSR”) concludes that Mr. Speights’ conduct
produces a total offense level of 20, See PSR ¶¶ 69, a criminal history category VI See PSR ¶¶
108, and a guideline range of 70 to 87 months. Mr. Speights believes that in the interest of justice,
the imposition of a sentence below the guideline range is warranted based on the sentencing
considerations set forth in 18 U.S.C. § 3553(a).

1. A downward variance and a sentence beneath the stipulated range are
appropriate in this case.

1 This was not disclosed to the probation Officer during his Presentence interview.
Case 1:23-cr-00078-RGA Document 52 Filed 09/12/25 Page 3 of 32 PageID #: 177

Honorable Richard G. Andrews, U.S.D.J.
September 12, 2025
Page 3

As this Court is aware, the procedural requirements of post-Booker sentencing are well
established. Briefly, sentencing courts must (1) properly calculate the Guidelines range; (2) rule
on any departure motions made under the Guidelines; and (3) exercise post-Booker discretion by
choosing a sentence in light of all relevant sentencing factors under 18 U.S.C. § 3553(a),
“regardless [of] whether [the chosen sentence] varies from the sentence calculated under the
Guidelines.” United States v. Gunter, 462 F.3d 237, 247 (3d Cir. 2006). The Court’s final
determination on a sentence must reflect “§ 3553(a)’s overreaching instruction to ‘impose a
sentence sufficient, but not greater than necessary’ to accomplish the sentencing goals advanced
in § 3553(a)(2).” United States v. Kimbrough, 128 S. Ct. 558, 575 (2007). Those purposes can
best be summarized as punishment, deterrence, incapacitation, and rehabilitation.

The “sufficient, but not greater than necessary” requirement is often referred to as the
“parsimony provision.” The parsimony provision is not simply another factor to be considered
along with the others set forth in § 3553(a); it actually imposes a separate and independent limit
on the sentence a court may impose. See United States v. Denardi, 892 F.2d 269, 276-77 (3d Cir.
1989) (Becker, J., concurring in part, dissenting in part) (since § 3553(a) requires the sentence to
be no greater than necessary to meet four purposes of sentencing, imposition of a sentence greater
than necessary to meet those purposes is reversible, even if within the guideline range). Thus,
under § 3553(a), courts are required to impose a sentence below the guideline range if such a
sentence would be sufficient to achieve the purposes of sentencing.

In determining the sentence minimally sufficient to comply with the § 3553(a)(2) purposes
of sentencing, the court must consider several factors listed in § 3553(a). In applying
the relevant factors to Mr. Speights and the instant offense, counsel submits that a sentence below
the guidelines meets both the mandate and the purposes of 18 U.S.C. §3553(a).

(a) The 18 U.S.C. §3553(a) Factors

1. Nature and circumstances of the offense and history and characteristics of
the defendant.

Mr. Speights does not argue that bank fraud and money laundering are not serious crimes.
He knows and accepts that his conduct was not only unlawful; it was detrimental to the welfare
and stability of his community and his victims. He is remorseful and has continuously apologized
for his conduct. He accepts the fact he owes society a debt. (See Mr. Speights’ letter attached as
Exh. A). His motivation for engaging in this conduct was fueled by psychological trauma. He was
propelled by the erroneous belief that he could enhance his stature by giving money away.
Providing others with gifts and financial help made him feel needed and important. His fraudulent
and deceptive behavior took on an addictive nature. He believed it was the only way he could
satisfy loneliness, emptiness and a feeling of shame and lack of self-worth. Unfortunately, his
self-imposed and self-created financial pressures led to a series of bad and regrettable decisions.
Case 1:23-cr-00078-RGA Document 52 Filed 09/12/25 Page 4 of 32 PageID #: 178

Honorable Richard G. Andrews, U.S.D.J.
September 12, 2025
Page 4

He has already embarked on a path of self-improvement. During his time in custody, he has
used his time extremely productively. He has taken numerous educational courses to enable him
to better adjust to society and become a productive member. (See Exhibit B).

2. The need for the sentence imposed to reflect the seriousness of the offense, to
promote respect for the law, and to provide just punishment for the offense.

Mr. Speights acknowledges that some punishment must be imposed to reflect the
seriousness of this offense, promote respect for the law, provide punishment and deterrence, and
protect the public. An evaluation of Mr. Speights’ conduct suggests that a sentence below the
guideline is appropriate. Mr. Speights has been incarcerated for nearly one year. He has already
begun to pay his debt to society. He is remorseful and has vowed to never again be involved in
criminal conduct. He is disappointed in himself and yearns to become a valuable and viable
member of society. He has been forthright and honest about his conduct. He met with law
enforcement and truthfully told authorities everything concerning his involvement. He fully
accepts the consequences of his conduct. He remains hopeful that he will be allowed to go back
to his family and create a productive life.

3. The need for deterrence to protect the public from further crimes of the defendant.

Mr. Speights has been in custody nearly a year. He is 43 years old. The need to
deter Mr. Speights from future criminal conduct should be a minor concern. He has never been
involved with any gangs or any acts of violence. The embarrassment he caused his family is an
adequate deterrence. His involvement with fraudulent conduct was driven by a need for
recognition and importance. This need was brought on by years of sexual abuse and psychological
trauma. It manifested itself through foolish fraudulent conduct. It resulted in poor decisions, and
he is ashamed and remorseful. His involvement in this case was partially driven and orchestrated
by someone that he trusted. A false spiritual sexual predator recognized Crandall’s vulnerability
and preyed on it. As a result, he was aided and encouraged in making poor decisions. He
understands and regrets the pain, agony and shame he caused his family. The general threat of
incarceration that looms behind any criminal undertaking, along with the potential separation from
his loved ones, serves as an adequate deterrent to him. He is determined never to go back to jail
and promises to create a productive and meaningful life. He admits that he made poor choices.
He regrets his past decisions. He understands and regrets the harm he caused to victims. He regrets
the pain, agony and shame he caused his family. The public and society also do not and will not
need protection from Mr. Speights. He has never been involved with any act of violence. He vows
never again to be involved with any criminal activity. A loving and caring family surround him.
Case 1:23-cr-00078-RGA Document 52 Filed 09/12/25 Page 5 of 32 PageID #: 179

Honorable Richard G. Andrews, U.S.D.J.
September 12, 2024
Page 5

Although very hurt and ashamed of his conduct, he has many friends and family members that
continue to support him. (See letters of support attached as Exh. C).

The need to provide the defendant with needed educational or vocational training,
medical care, or other correctional treatment in the most effective manner

A careful analysis of the § 3553(a) factors indicates that Mr. Speights’ sentence should fall
below the guideline minimum. Mr. Speights is 43 years old. Unfortunately, he has serious medical
issues. He suffers from a possibly deadly communicable illness. He suffers from issues regarding
his heart. He suffers from Type one diabetes and Asthma. He is taking numerous prescribed
medications. See PSR ¶¶ 150. He needs constant and ongoing medical care and attention. He
needs psychological counseling to address his childhood trauma and sexual identity. Prisons are
not conducive environments to address the needs of those who are physically and mentally ill. A
lengthy prison sentence will exacerbate his medical illnesses and is contrary to the requirement of
providing adequate medical care.

CONCLUSION

Mr. Speights is forty-three years old. He is in poor health and in need of medical care. He
continues to suffer from childhood trauma from being sexually abused. He has accepted his
responsibility. He willingly told the authorities everything they wanted to know about his conduct
without a lawyer. He demonstrated and expressed his remorse. He is a changed man. He is older
and wiser. The goals of sentencing can certainly be met by a sentence below the guideline range.
Accordingly, Mr. Speights respectfully and prayerfully requests a downward variance and asks
this Court to sentence him to a term that is minimally sufficient and is less than the guideline
minimum.

Respectfully submitted,

____________________________________
Stanley O. King

Enclosures

cc: Carly Hudson, A.U.S.A.
Michael Menago U.S.P.O.
Crandall Speights
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