Sixth Circuit upholds convictions in Black Lives Matter fundraiser fraud case
United States v. Sir Maejor Page. United States Court of Appeals for the Sixth Circuit. Docket: No. 24-3871.
The Sixth Circuit upheld Sir Maejor Page’s convictions and a 42-month sentence after finding strong evidence that he misled donors about how a “Black Lives Matter” named group would use their money.
Holding
The court affirmed Page’s wire fraud and money laundering convictions and rejected his trial and sentencing challenges. It also upheld the district court’s Guidelines calculations, including enhancements for perjury, loss amount, and number of victims.
Why It Matters
A “not tax-exempt” disclaimer did not cure misrepresentations about how donations would be used.
When a fraud scheme is pervasive, courts may treat the full amount raised as “loss” if it is not practical to separate legitimate spending.
Victim counts for U.S.S.G. §2B1.1 can rest on reasonable inferences from the record. The court did not require the judge to name individual victims when the evidence showed that thousands of donors were involved.
Evidence of spending that clearly conflicts with stated charitable purposes can b…
