In the Courts

In United States v. Rogers, 321 F.3d 1226 (9th Cir. 2003), appellant Rogers was convicted of one count of mail fraud in violation of 18 U.S.C. ' 1341 relating to the mailing of a cashier's check of $5000, and five counts of money laundering in violation of 18 U.S.C. ' 1957 relating to the shuffling between accounts of larger amounts of funds. A conviction for money laundering under 18 U.S.C. ' 1957 requires the government to show: 1) the defendant knowingly engaged in a monetary transaction; 2) he or she knew the transaction involved criminal property; 3) the property's value exceeded $10,000; and 4) the property was derived from a specified unlawful activity. See United States v. Messer, 197 F.3d 330, 341 (9th Cir. 1999). Mail fraud is included as such a 'specified unlawful activity.' 18 U.S.C. ' 1957(f)(3); 18 U.S.C. ' 1956(c)(7)(A); 18 U.S.C. ' 1961(1). To establish mail fraud under 18 U.S.C. ' 1341, the government must establish: 1) proof of a scheme to defraud; 2) using or causing the use of the mails to further the fraudulent scheme; and 3) specific intent to defraud. See United States v. Munoz, 233 F.3d 1117, 1129 (9th Cir. 2000).