Case Explained: United States v. Lacona

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-07-01 Docket: 1:23-CR-00104-DDD-1) The Tenth Circuit affirmed Charles Lacona’s convictions for two counts of wire fraud and one count of money laundering. The court held that the government presented sufficient evidence to establish the required interstate-commerce link for the wire-fraud charges, finding that a rational jury could conclude Lacona knowingly submitted loan applications via digital means to an out-of-state bank, thereby foreseeing that his fraudulent scheme would involve interstate wire communications used to process fees and disburse funds. Regarding constructive amendment, the court ruled that the government did not broaden the indictment; it maintained a single theory of a unified fraud scheme throughout the trial, and the proof presented corresponded to the offenses charged in the indictment. Furthermore, the court found no prosecutorial misconduct, determining that the prosecutor’s closing argument statements regarding an accountant’s records were proper summaries of admitted evidence rather than improper assertions of facts not in evidence. As a practical consequence, Lacona’s convictions stand, and he remains subject to his original sentence of 24 months in prison, three years of supervised release, and nearly $550,000 in restitution. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.