United States v. Taylor

Dewey Taylor (defendant) owned a liquor store and belonged to the Buffalo, New York, chapter of a motorcycle group. Other members of the group were investigated by federal authorities for drug distribution. In connection with the investigation, Taylor was charged in federal district court with several counts of transaction structuring for the purpose of evading financial-institution reporting requirements. At trial, the government (plaintiff) primarily relied on Taylor’s transaction history at Erie Metro Federal Credit Union (Erie Metro) to show a pattern of structured transactions and prove that Taylor intended to evade reporting requirements. The transaction records showed that Taylor made numerous deposits at Erie Metro into both his personal and business accounts over a 20-month period. These deposits included seven split cash transactions, each involving two deposits, on which the criminal structuring charges were based. In each split transaction, Taylor presented both deposits to one teller at one Erie Metro branch that together exceeded $10,000. The records from this period also showed Taylor frequently made single deposits exceeding $10,000, which were subject to reporting. Evidence presented to the jury showed that Taylor’s business involved large amounts of cash, and that Taylor often immediately used the deposited cash to pay expenses for his liquor store. Taylor was convicted of several counts of illegal transaction structuring, and he appealed.