Case Explained: UNITED STATES OF AMERICA v. SHELITHA RENEE ROBERTSON

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-05 Docket: 1:22-cr-00432-SDG-JEM-1 The eleventh-circuit affirmed the conviction and sentence of Shelitha Robertson for wire fraud, conspiracy to commit wire fraud, and money laundering. The court held that the evidence presented at trial was sufficient to support the jury’s verdict under the standard that a conviction must be upheld unless no rational trier of fact could find the essential elements of the crime beyond a reasonable doubt. Specifically, the court found ample evidence that Robertson intentionally participated in a scheme to defraud the Paycheck Protection Program (PPP) by submitting fraudulent applications claiming non-existent employees, and that she knowingly aided and abetted her co-conspirator, Chandra Norton, in this conduct. Regarding the sentencing and restitution orders, the court applied the clear error standard and rejected Robertson’s arguments that she should not be liable for losses attributable to Norton or that repayment of funds before detection should reduce the loss amount. The court determined that the district court correctly calculated the loss at approximately $14.9 million based on jointly undertaken criminal activity, noting that Robertson repaid the funds only after the banks detected the fraud and froze accounts, which precluded credit under U.S.S.G. § 2B1.1. Furthermore, the court held that the district court properly ordered joint and several restitution for the full $4.4 million loss incurred by the Small Business Administration under the Mandatory Victim Restitution Act. The court also addressed procedural challenges, ruling that the district court did not abuse its discretion in admitting lay opinion testimony from an SBA employee regarding PPP procedures, allowing Norton to provide context for recorded conversations based on her first-hand knowledge under Federal Rule of Evidence 701, and using summary charts as demonstrative aids rather than evidence. Additionally, the court found no reversible error in the district court’s deliberate ignorance jury instruction, stating that even if erroneous, any such error was harmless given the evidence supporting actual knowledge. Consequently, Robertson’s conviction stands, and her sentence of 87 months in prison and three years of supervised release remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.