United States v. Collis

Ronald Collis (defendant) was convicted for embezzlement and sentenced to imprisonment and supervised release. After Collis was released from prison, he pleaded guilty to a state charge of embezzlement. Upon learning that Collis had committed an offense while on supervised release and had left the district without permission, Collis’s probation officer filed a petition to revoke Collis’s supervised release. The district court concluded that Collis had violated his supervised release. Before sentencing, Collis’s lawyer submitted three letters that he had received from Collis. One letter was purportedly signed by the owner of the firm where Collis had been working but turned out to be fabricated and forged by Collis. The letter stated that Collis was an ideal employee, had been trying to rehabilitate himself under the care of a psychologist, had been doing community service, had authored a published article on how to avoid employee embezzlement, was going to represent the Michigan Association of CPAs (Certified Public Accountants) at a high school career day, and had been making restitution payments. The letter asked that the judge consider alternatives to incarceration. Collis was indicted and convicted of obstruction of justice based on the letter. On appeal, Collis argued that the obstruction charge should not have been based on the letter because there was no evidence that the letter affected the court’s determination of guilt or the sentence imposed.