Wire-Fraud “Scheme” Completes Upon Misrepresentation, Supporting Money-Laundering Counts and Full-Donation Loss in Charitable-Donation Fraud

Introduction

In United States v. Sir Maejor Page (6th Cir. Dec. 30, 2025), the Sixth Circuit affirmed the convictions and sentence of Sir Maejor Page for wire fraud and money laundering arising from a high-profile fundraising scheme tied to Black Lives Matter-related activism in 2020.

Page created a Facebook presence for “Black Lives Matter of Greater Atlanta” (BLMGA) and received nearly $490,000 in donations through Facebook’s fundraising tools. Donors believed funds would support protests and social-justice efforts; the government proved Page instead spent the money on personal purchases (including a house in Toledo, tailored suits, alcohol/entertainment, firearms, and a prostitute). After trial convictions, the district court applied Guidelines enhancements for obstruction (perjury), loss amount, and number of victims, ultimately imposing a below-Guidelines 42-month sentence.

On appeal, Page raised four main clusters of issues: (1) sufficiency of evidence for wire fraud and money laundering; (2) alleged variance between indictment and proof; (3) evidentiary error (Rule 403, Rule 608/609, and character-evidence rules); and (4) procedural unreasonableness in Guidelines calculations (obstruction, loss, victims).

Summary of the Opinion

The Sixth Circuit (Thapar, J.) affirmed across the board.

Sufficiency (wire fraud): Because Page failed to renew his Rule 29 motion, review was limited to “manifest miscarriage of justice,” and the record plainly contained evidence of a scheme to defraud and intent to deprive donors of money.
Sufficiency (money laundering): The court held the wire-fraud offense (a “scheme to defraud”) can be “completed” for § 1957 purposes upon misrepresentation (a completed phase of an ongoing scheme), and the jury could find the house funds were fraud proceeds and that Page knew they were criminally derived.
Variance: No variance; the trial evidence matched the indictment’s core allegation: soliciting/receiving donations through misrepresentations and using them for personal benefit.
Evidentiary rulings: Firearms and prostitution evidence was properly admitted under Rule 403; cross-examination about impersonating an officer was permitted under Rule 608(b); some rebuttal character evidence violated Rule 405 but did not amount to plain error given overwhelming evidence of guilt.
Sentencing: No clear error in applying enhancements for obstruction by perjury, full $490,000 loss, and 10+ victims.

Analysis

Precedents Cited

1) Sufficiency of the evidence: forfeiture and the “manifest miscarriage of justice” standard

The opinion’s sufficiency review turned on procedure. Because Page raised a Rule 29 motion after the government’s case but did not renew it after presenting his own evidence, the Sixth Circuit applied the stringent standard described in United States v. Dunnican: reversal is warranted only if “the record is devoid of evidence pointing to guilt.”

For the wire-fraud elements, the court relied on the articulation in United States v. Palma (scheme to defraud, use of interstate wires, and intent to deprive money or property) and rejected undeveloped arguments under the forfeiture principle emphasized in United States v. Persaud.

2) Wire-fraud misrepresentations and the effect of partial disclosures

Page argued that he disclosed BLMGA’s loss of nonprofit status and contacted Facebook about removal. The court treated this as inadequate to negate fraud because he still reassured donors their funds would be used for protest-related purposes, and he did not disclose the personal spending. In assessing how disclaimers interact with fraud proof, the court cited United States v. Maddux for the proposition that selective disclosures do not necessarily defeat a finding of deceptive intent where the overall impression remains misleading.

On the jury’s role and appellate restraint, the court invoked United States v. Miller and United States v. Acosta to explain that appellate courts do not reweigh evidence and must draw reasonable inferences in the government’s favor, including inferences that “legitimizing” steps may be concealment rather than good faith.

3) Money laundering: proceeds, timing, and “completed phase” doctrine

The opinion applied the Sixth Circuit’s three-element test for concealment money laundering under § 1956(a)(1)(B)(i) from United States v. Warshak, and it relied on United States v. Prince for the proposition that money wired by victims can constitute proceeds of wire fraud.

For § 1957, the court quoted the elements from United States v. Persaud and the “already completed offense, or a completed phase o[f] an ongoing offense” requirement from United States v. Kerley.

Critically, the court rejected Page’s “timing” challenge (wire-fraud scheme alleged to run through September; laundering purchases in August). Relying on United States v. Chavez (quoting Neder v. United States), the court emphasized that wire fraud criminalizes the “scheme to defraud,” not “completed fraud,” and “liability doesn’t wait to attach until after the victim falls for the ruse.” This reasoning supplied the bridge to Kerley: once Page made material misrepresentations (a completed phase of the scheme), subsequent transactions using donor money could satisfy § 1957’s “criminally derived” requirement even if the overall scheme continued.

4) Variance and plain-error review

Because Page did not raise variance below, the court applied plain-error review under United States v. Vonner. It defined variance using United States v. Robinson: a variance occurs when the indictment’s charging terms remain the same but the trial proves materially different facts. The court found no variance because the evidence tracked the indictment’s alleged misrepresentations and personal diversion of funds.

5) Evidence: Rule 403 balancing, impeachment, and character evidence

On Rule 403, the court relied on the deference framework from United States v. Johnson and the “maximum probative/minimum prejudicial” assumption from United States v. Harvel, stressing district courts’ “wide latitude” under United States v. Gibbs.

The firearms evidence was framed as not inherently inflammatory because lawful gun ownership is common; the court cited Staples v. United States for the observation that guns “generally can be owned in perfect innocence.” The prostitution evidence was analyzed through the distinction between “prejudicial” and “unfairly prejudicial,” citing United States v. Mercer-Kinser and Koloda v. Gen. Motors Parts Div., Gen. Motors Corp..

On impeachment, the court held Rule 609 did not control questioning about impersonating a police officer because there was no conviction; instead Rule 608(b) permitted inquiry into specific instances probative of truthfulness.

The most nuanced evidentiary discussion concerned character evidence. The court reiterated the “opening the door” principle (a defendant’s good-character evidence permits rebuttal) using Rule 404(a)(2)(A), United States v. Clark, and the foundational statement in Michelson v. United States. But it also enforced Rule 405’s limits: on direct examination, character generally must be proven by reputation or opinion, not specific acts. The court found error (though not plain error warranting reversal) in permitting two rebuttal witnesses to describe specific instances of Page’s conduct, relying on harmlessness principles from United States v. Warman. It also applied issue-forfeiture principles such as Doe v. Mich. State Univ. and explained the “new grounds on appeal” rule under United States v. Evans.

Finally, on cumulative error, the court applied United States v. Trujillo, concluding that the limited identified errors did not render the trial fundamentally unfair.

6) Sentencing: procedural reasonableness and enhancements

The court framed procedural reasonableness under Gall v. United States.

Obstruction (perjury): Applying § 3C1.1, the court cited United States v. Jackson (clear-error review) and United States v. O'Lear for the perjury elements and the requirement that the district court identify perjurious statements and make findings. It upheld the enhancement based on Page’s false testimony about consulting a lawyer before purchasing the house, and it deemed materiality satisfied under United States v. Bailey.
Loss amount: Under § 2B1.1, the court applied clear-error review per United States v. Riccardi and reiterated that reasonable estimates suffice under United States v. Rothwell. It relied heavily on United States v. Betro for the principle that when fraud is “pervasive,” the district court may treat the entire amount collected as loss, shifting the burden to the defense to prove reductions.
Victim count (10+): The court cited United States v. Abdelsalam (clear-error review), defined “victim” via United States v. Yagar, and approved reasonable inference-drawing under United States v. Parrish. Given evidence identifying over 18,000 donors, the court held it was reasonable to find at least 10 victims without individually naming them.

Legal Reasoning

1) The “scheme” concept does substantive work

A central doctrinal move is the court’s insistence that wire fraud punishes the “scheme to defraud,” making the offense (or at least a “completed phase” of it) operative before the scheme ends and before every victim is identified. This matters because Page’s money-laundering argument depended on treating wire fraud as incomplete until the final date alleged in the indictment. By characterizing Page’s early misrepresentations as completing a phase of the offense, the court preserved the statutory separation between predicate offense and laundering transactions while avoiding a rule that would immunize mid-scheme laundering.

2) Donor deception can be inferred from the fundraising context and misrepresentations

The court accepted that only six donors testified, but held the jury and sentencing court could infer broader deception from: (i) repeated representations about protest-related uses; (ii) the legitimizing effect of the “Black Lives Matter” label and Facebook’s nonprofit listing; and (iii) Page’s nondisclosure of personal uses. This approach treats mass-donation fraud like other scalable frauds: individualized testimony is helpful but not required where circumstantial evidence supports inference at both guilt and sentencing stages (beyond a reasonable doubt for conviction; preponderance for Guidelines facts).

3) Evidence of “personal spending” is not merely sensational—it is probative of intent and falsity

The Rule 403 analysis reflects an intent-focused theory of fraud proof: purchases inconsistent with the stated mission are highly probative of deceptive intent and the falsity of claims that donations would support movement objectives. The court also policed “unfair prejudice” by noting the government presented limited excerpts and avoided inflammatory detail, reinforcing that careful presentation can preserve probative value while mitigating prejudice.

4) Character rebuttal: permissible in principle, constrained in form

The opinion distinguishes between (i) the prosecution’s entitlement to rebut defense-crafted narratives of virtue (Rule 404(a) and Michelson v. United States) and (ii) the method of proving that rebuttal (Rule 405). Even where rebuttal is allowed, the government generally cannot use specific-act testimony on direct examination unless character is an essential element. The court found a Rule 405 violation but treated it as non-outcome-determinative on plain-error review because the fraud proof was overwhelming.

Impact

Money laundering in ongoing frauds: The opinion reinforces that, in the Sixth Circuit, laundering liability under § 1957 is not defeated merely because the indictment alleges an end date after the laundering transaction. If the defendant has already engaged in a completed phase of the fraud scheme (such as making deceptive representations), subsequent transactions can qualify as involving “criminally derived” proceeds.
Mass-donor and online fundraising prosecutions: The court’s willingness to infer deception across thousands of donors based on uniform misrepresentations and platform-driven legitimacy may make it easier to prove loss and victim counts in large-scale online donation cases, particularly where individualized donor testimony is impractical.
Sentencing exposure: By approving full-donation loss where fraud is “pervasive” (and placing the burden on defendants to identify legitimate offsets), the opinion underscores that defendants who commingle claimed “mission” spending with personal diversion face substantial Guidelines risk unless they can document bona fide, mission-linked expenditures.
Trial strategy consequences: The character-evidence discussion is a practical warning: defendants who foreground activism or virtue may “open the door” to rebuttal. While Rule 405 constrains the form of rebuttal, the door-opening itself can broaden the narrative battlefield.

Complex Concepts Simplified

“Scheme to defraud” (wire fraud): Wire fraud does not require the government to prove every donor was personally spoken to or that the fraud reached a “final completion” before criminal liability attaches. The crime is the plan and execution of deception using interstate wires, coupled with intent to take money or property.
“Proceeds” and “criminally derived funds” (money laundering): Money becomes “proceeds” once obtained through unlawful activity (here, wire fraud). For § 1957, the money must come from an already completed crime or a completed stage of an ongoing crime—so mid-scheme transactions can still be laundering if the fraud has already progressed past key criminal steps (like material misrepresentations that set the scheme in motion).
Standards of review matter:
- Manifest miscarriage of justice is extremely hard for defendants: the appellate court looks only for whether the record is essentially empty of guilt evidence.
- Plain error (for unpreserved issues) requires not just a mistake, but a clear one that likely changed the outcome and seriously undermines the proceedings’ fairness.
Rule 403 (“unfair prejudice”): Courts do not exclude evidence merely because it makes the defendant look bad; exclusion is for evidence likely to provoke an irrational verdict that substantially outweighs legitimate probative value.
Rule 404 vs. Rule 405 (character evidence): Rule 404 controls when character evidence is allowed; Rule 405 controls how it can be proven. Even when rebuttal is allowed, Rule 405 usually limits proof to reputation/opinion rather than “here’s what he did on a specific occasion.”
Guidelines “loss” and “victims”: “Loss” is typically the money victims were induced to part with. “Victims” are people who suffered actual financial loss. In large frauds, courts may use reasonable inferences and estimates rather than requiring individualized proof for every donor.

Conclusion

United States v. Sir Maejor Page affirms a straightforward fraud-and-laundering prosecution but carries broader significance for modern, platform-mediated fundraising misconduct. The Sixth Circuit underscored that wire fraud targets the deceptive “scheme,” enabling money-laundering convictions for transactions occurring during an ongoing scheme so long as a completed phase of the fraud has already occurred. The decision also illustrates how courts treat large-scale donor fraud at sentencing—often using full-donation loss and inferring widespread victimization where misrepresentations are uniform and the evidence of diversion is overwhelming—while providing a cautionary note on character evidence: defendants who put virtue at issue invite rebuttal, though prosecutors remain constrained by Rule 405’s methods of proof.