United States v. Mitchell Melega

── United States v. Mitchell Melega ── Court: Court of Appeals for the Seventh Circuit Date: April 24, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 24-2298 UNITED STATES OF AMERICA, Plaintiff-Appellee, v. MITCHELL A. MELEGA, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Central District of Illinois. No. 4:20-cr-40056-JES-JEH-2 — James E. Shadid, Judge. ____________________ ARGUED SEPTEMBER 17, 2025 — DECIDED APRIL 24, 2026 ____________________ Before SCUDDER, PRYOR, and KOLAR, Circuit Judges. SCUDDER, Circuit Judge. Mitchell Melega appeals his 75- month federal sentence for conspiracy, bank fraud, and money laundering based on his role in a multimillion-dollar scheme to defraud two banks. In calculating the advisory sen- tencing range, the district court applied one two-level en- hancement for Melega’s use of sophisticated means and an- other for his role in the offense. The court then sentenced him below the advisory range. Melega challenges both 2 No. 24-2298 enhancements, the district court’s reliance on certain facts, and its application of the sentencing factors under 18 U.S.C. § 3553(a). We affirm. I A Mitchell Melega served as financial controller for I-80 Equipment LLC, a company owned by his co-defendant, Erik Jones, that bought, refurbished, and sold used vehicles. As controller, Melega managed the company’s borrowing and participated in management decisions. He held a similar fi- nancial role in Jones’s property management and rental com- pany, J.P. Rentals LLC. From about August 2016 to November 2017, Melega and Jones ran a scheme to defraud two regional banks, First Mid- west Bank and Northwest Bank, through I-80 and J.P. Rentals. The fraud on each bank followed a similar pattern—Melega and Jones leveraged false promises, and for First Midwest Bank, forged documents, to obtain loan advances for work their companies did not plan to undertake. They then di- verted the funds and failed to repay the debt. The fraud committed through I-80 focused on vehicle loans. Jones executed loan agreements on the company’s be- half with First Midwest Bank under which the bank agreed to provide 80% of the capital needed to buy and improve vehi- cles. I-80 documented purchases with these funds and tracked the vehicles using vehicle identification numbers. The com- pany owed the principal and interest once it sold a vehicle. But I-80 instead diverted the funds through the following process. Melega would start with a list of vehicles from a sup- plier. Someone—we do not know who—then altered the No. 24-2298 3 invoices to inflate purchase prices. Melega knowingly submit- ted the fraudulent invoices, as well as unaltered invoices for vehicles I-80 did not buy, to First Midwest along with a loan- advance request. He also requested funds for improvements to vehicles that I-80 had not purchased. Unbeknownst to the bank, I-80 never intended to buy or improve many of these vehicles. In addition to coordinating the loan applications, Melega directed employees to make excuses for missing vehi- cles when bank inspectors visited I-80. Melega and Jones perpetrated a similar scheme to defraud Northwest Bank through Jones’s rental company. Jones exe- cuted a loan agreement with the bank on behalf of J.P. Rentals to buy and renovate an apartment complex. Northwest Bank later discovered that the improvements associated with cer- tain loan advances were never made. At some point, Jones and Melega discussed diverting funds to pay I-80’s debts. In the end, Melega and Jones’s scheme caused over $7,000,000 in losses to Fi