United States v. Kitts, No. 19-1325 (1st Cir. 2022)
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The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.
On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing.
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