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 be highly probative of intent, even if it looks ugly.
Timeline
2014: Page forms “Black Lives Matter of Greater Atlanta” (BLMGA) and sets up a Facebook presence and bank account.
2019: IRS revokes BLMGA’s tax-exempt status after missing filings.
May–Sept. 2020: After George Floyd’s death, donations surge. More than $490,000 flows into the BLMGA account.
March 2021: Grand jury indicts Page for wire fraud and money laundering.
Trial: Page testifies. Jury convicts on all counts.
Sentencing: District court calculates 70–87 months under the Guidelines but imposes 42 months.
Dec. 30, 2025: Sixth Circuit affirms.
Key Facts
Facebook’s fundraising tool listed BLMGA as a tax-exempt nonprofit, which made it easy for users to find it by typing “Black Lives Matter.”
Even after the IRS revoked BLMGA’s tax-exempt status, BLMGA stayed listed on Facebook because Page did not complete Facebook’s follow-up steps to remove it.
Page told users that donations would support protests and related needs, such as supplies, food, attorney fees, and bail.
Donations surged to more than $490,000 in a few months.
Page used funds for personal spending, including:
About $108,000 toward a house in Toledo, Ohio, plus renovation and furnishing expenses.
Tailored suits and other menswear.
Firearms and ammunition.
A paid encounter with a prostitute, including a recorded conversation referencing “red flags.”
Statutory or Regulatory Framework
Wire fraud requires proof of a scheme to defraud, use of interstate wires, and intent to deprive victims of money or property.
Money laundering convictions here involved:
18 U.S.C. §1956(a)(1)(B)(i), which covers transactions designed to conceal or disguise proceeds.
18 U.S.C. §1957, which covers monetary transactions over $10,000 using criminally derived property.
Sentencing issues applied:
U.S.S.G. §3C1.1 obstruction of justice, which applies to perjury.
U.S.S.G. §2B1.1 loss amount and victim-count enhancements.
Arguments
Page argued:
The evidence did not support wire fraud or money laundering.
The proof at trial varied from the indictment.
The district court admitted unfairly prejudicial evidence (firearms and prostitute-related evidence).
The government improperly used character evidence.
The district court misapplied Guidelines enhancements for perjury, loss, and victims.
Government argued:
Page repeatedly misrepresented how donations would be used and then spent the money on personal items.
Donors were deceived into giving money they would not have donated otherwise.
The money used for the house and related purchases came from the fraud proceeds and supported money laundering counts.
The record supported the Guidelines findings.
Court’s Reasoning
Sufficiency of evidence (procedural posture mattered): Page did not renew his Rule 29 motion after presenting evidence, so the court reviewed for “manifest miscarriage of justice.” The record was not “devoid of evidence” of guilt.
Wire fraud: The court pointed to repeated donor interactions in which Page assured users that funds would support protest-related purposes, in contrast to spending on personal lifestyle. That pattern supported both scheme and intent.
Disclaimers did not fix the problem: Telling donors BLMGA was not tax-exempt did not disclose that funds would be used for personal expenses.
Money laundering:
The court rejected the claim that only the six testifying donors were deceived. The jury could reasonably infer broader deception from the organization’s branding, the donor communications, and the flow of donations.
For §1957 timing, the court explained that wire fraud criminalizes the scheme, not only a fully completed end-state. Funds can qualify as criminally derived even if the overall scheme continued beyond the transactions.
Evidentiary rulings:
Firearms and prostitute-related evidence had high probative value on intent and misuse of funds and was not unfairly prejudicial under Rule 403 as presented.
Cross-examination about impersonating an officer was appropriate under Rule 608(b) as conduct bearing on truthfulness.
The court found an error in the Rule 405 limits for two character witnesses describing specific acts, but held it harmless given the strength of the government’s proof.
Sentencing:
Perjury enhancement: The district court identified the false testimony and explained willfulness and materiality.
Loss amount: Treating the full $490,000 as loss was reasonable given the pervasiveness of the fraud and the lack of a reliable basis to net out legitimate spending.
10+ victims: The record supported far more than ten donors suffering loss. The court allowed reasonable inferences without requiring the judge to name victims.
Result
The Sixth Circuit affirmed the convictions and sentence in full.
The Takeaway
If you raise money using a charitable brand, you need clean disclosures and spending that matches the pitch. A partial disclaimer about tax status will not protect you if your actual message to donors says “this supports the cause” and your bank records say “this supports my lifestyle.”