Rohan Lyttle, a Jamaican national residing in New York, managed a complex criminal enterprise involving his ex-wife, son, and former partner to defraud elderly Americans through an advance-fee lottery scam. The scheme involved a fake persona named 'Andrew Goldberg' who contacted victims claiming they had won sweepstakes prizes, requiring them to prepay taxes and fees to receive the money. Lyttle and his co-conspirators used a network of businesses, including an auto body shop in New York and a used car dealership in Jamaica, to launder the illicit funds. Victims were instructed to wire money, mail cash, or purchase and ship vehicle parts to the defendants' locations. After a nine-day jury trial, Lyttle was convicted on multiple counts including conspiracy to commit wire and mail fraud, wire fraud, mail fraud, transportation of goods taken by fraud, and conspiracy to launder monetary instruments. He was sentenced to 97 months in prison and ordered to pay over $245,000 in restitution. Lyttle appealed, arguing the evidence was insufficient to support the wire fraud conviction, the sentencing enhancement was improper, and the trial court erred in admitting YouTube videos as evidence.
The Third Circuit addressed three primary issues on appeal. First, regarding the sufficiency of evidence for wire fraud, the court applied a plain error standard because Lyttle failed to specifically argue that the use of a credit card was unforeseeable in the District Court. The court explained that to prove wire fraud, the government must show the defendant knowingly participated in a scheme to defraud with the specific intent to defraud, and that the use of interstate wires was reasonably foreseeable. The court found that a rational jury could conclude Lyttle should have foreseen that a purchaser of over $15,000 in auto parts might use a credit card, especially given that large purchases are typically made electronically. The court noted that Lyttle accepted the parts and the vehicle was repaired and shipped, confirming his knowledge of the transaction. Second, the court reviewed the application of the three-level managerial enhancement under U.S.S.G. § 3B1.1(b). The court clarified that a 'manager or supervisor' is someone who exercises some degree of control over others involved in the offense. Relying on the District Court's findings that Lyttle educated his co-conspirators on how to operate the business entities to maximize cash flow and profits and carefully delegated tasks to perpetuate the fraud, the court held that Lyttle exercised the necessary oversight. The court emphasized that this enhancement applies to the charged criminal activity, not just legitimate business operations. Third, the court addressed the admission of Exhibits 220 and 369, which included a YouTube news clip about Jamaican lottery scams and a browser history summary. The court found no abuse of discretion, noting that the videos were relevant to show the defendant's knowledge of how such scams work. The District Court had properly limited the scope of the video and instructed the jury to use it only to determine familiarity with the scam type, not as evidence of wrongdoing itself.
The judgment of the District Court is affirmed, meaning Lyttle's conviction and 97-month sentence stand. The decision reinforces that defendants in fraud schemes are liable for foreseeable electronic transactions even if they instructed victims to pay in cash. It also clarifies that individuals who manage legitimate businesses used to launder fraud proceeds can be sentenced as managers of the criminal enterprise if they exercise control over the criminal operations. The ruling confirms that courts have broad discretion to admit evidence of a defendant's research into scam methodologies to prove knowledge, provided limiting instructions are given.