United States v. Della Rose
United States District Court for the Northern District of Illinois
278 F. Supp. 2d 928 (2003)
- Written by Kelli Lanski, JD
Facts
Steven Della Rose (defendant) drafted a check out of a client trust account he controlled in Illinois and asked a man named Dennis Ilenfeld to cash the check at a bank in Chicago. Ilenfeld used phony identification in the client’s name to cash the check, defrauding the client out of the money. Della Rose was convicted of mail fraud and conspiracy to produce false identification in violation of the False Identification Crime Control Act of 1982. Della Rose argued that the government failed to present sufficient evidence of interstate commerce for the conspiracy charge. The government argued that it needed to prove only that there was a false identification document and a cashed check to sustain a conviction.
Rule of Law
Issue
Holding and Reasoning (Coar, J.)
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