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United States v. Armbruster

48 F.4th 527 (2022)

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United States v. Armbruster

United States Court of Appeals for the Seventh Circuit
48 F.4th 527 (2022)

Facts

Peter Armbruster (defendant) was the chief financial officer of Roadrunner Transportation Systems, Inc. (Roadrunner). Morgan Southern was a subsidiary of Roadrunner. Morgan Southern’s controllers discovered various shortcomings in Morgan Southern’s accounting practices, which resulted in an inflated balance sheet due to inaccurate information about a receivable asset and prepaid taxes. Despite having been alerted by Morgan Southern’s controllers about the accounting problems, Armbruster approved the filing of a Form 10-Q that contained material misstatements about Morgan Southern’s balance sheet. Armbruster was criminally charged with violating federal securities laws. The government relied on circumstantial evidence to show that Armbruster willfully falsified accounting records, committed securities fraud with the intent to deceive, and fraudulently induced Roadrunner’s auditors into filing a false Form 10-Q. The circumstantial evidence included witness testimony and corroborating documents indicating that Armbruster was aware of and ignored the accounting problems. The jury found Armbruster guilty. Armbruster appealed, arguing that the guilty verdict could not be sustained in the absence of any direct evidence that Armbruster acted willfully.

Rule of Law

Issue

Holding and Reasoning (Scudder, J.)

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