United States v. Sprick

Michael Sprick (defendant) was a financial advisor who stole some of his clients’ money for his personal use. Sprick learned that he was facing possible bank-fraud charges and attempted to email a radio personality. In the email, Sprick admitted that he had stolen a large amount of money from his clients. Sprick also acknowledged that he was likely going to face criminal charges and admitted that he was guilty. Sprick ended the email by admitting that he had done something wrong but claiming that he had done it for love, to try to make a woman happy. Due to an error in the email address, the email was never sent. However, the unsent email was found during a search of Sprick’s personal computer after his arrest. Sprick was charged not only with bank fraud but also with mail fraud and money laundering. The unsent email message was admitted as evidence at Sprick’s trial. The trial court instructed the jury that it was allowed to consider the message in deciding the bank-fraud charges that Sprick impliedly referenced in the email but not the later-added mail-fraud and money-laundering charges. Sprick was convicted of one of six bank-fraud charges but was convicted of all the mail-fraud and money-laundering charges. Sprick appealed, arguing that evidence of the unsent email was unfairly prejudicial and should have been excluded under Rule of Evidence 403.