Summary of a Recent
Judicial Development in
Finance & Credit

Farm Service Agency Employees Conspire to Defraud the Government

Walt McCarter
National AgLaw Center Research Associate

Summary of Decision

In United States v. Alfonzo-Reyes, 384 F. Supp. 2d 523 (D.P.R. 2005), the United States District Court for the District of Puerto Rico held that there was sufficient evidence in the record to sustain a defendant's convictions of conspiracy to defraud the federal government.

Background

From 1998 to 2000 several farmers, along with Farm Service Agency (FSA) employees, conspired to fraudulently obtain emergency funds from the federal government. Id. at 525. The defendants were convicted of numerous charges, including conspiracy to defraud the United States government through false pretenses and bribery of public officials in the process of obtaining hurricane-relief funds, and appealed. Id. at 525-26. Defendants Ismael Alfonzo-Reyes and Vanessa Morales-Hernandez moved for acquittal.

Arguments

The defendants challenged the sufficiency of the evidence presented at trial. Id. at 526.

Analysis and Holdings

To prove a violation of 18 U.S.C § 1014, the government must prove beyond a reasonable doubt that the defendant either knew the statement was false or acted with a conscious purpose to avoid learning the truth. Id. at 527. Alfonzo, an FSA employee, argued that the government had failed to provide sufficient evidence to satisfy the requisite knowledge element-that he knew the loan documents he prepared contained false information. Id. Alfonzo's co-defendants had testified that Alfonzo knew that the information in the documents was false and that he was offering to process fraudulent loan applications in return for a portion of the funds, so the court concluded that a reasonable jury could have found him guilty beyond a reasonable doubt. Id. at 528-33. The court likewise held that Alfonzo's convictions of charges brought under 18 U.S.C. § 208 (personal interest in financial dealings) and 18 U.S.C. § 209 (accepting bribes) were supported by the evidence. Id. at 533-35. The court therefore denied the defendant's motion for judgment of acquittal and sustained the jury verdict. Id. at 535.

In response to Mrs. Morales' assertion that the testimony present against her was not sufficient evidence, the court held that a reasonable jury could have found her guilty beyond a reasonable doubt based on the testimony presented, and upheld the verdict against her. Id.

The case was decided on July 29, 2005.