United States v. LaShawnda Alexander

── United States v. LaShawnda Alexander ── Court: Court of Appeals for the Sixth Circuit Date: May 18, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0219n.06 Case No. 25-3061 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 18, 2026 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE SOUTHERN DISTRICT OF ) OHIO LASHAWNDA ALEXANDER, ) Defendant-Appellant. ) OPINION ) Before: SILER, MOORE, and BLOOMEKATZ, Circuit Judges. SILER, Circuit Judge. Defendant Lashawnda Alexander appeals directly from her convictions for wire fraud in violation of 18 U.S.C. § 1343. Specifically, Alexander contends that the district court violated her constitutional right to present a defense and that she is entitled to relief on cumulative error. We AFFIRM. I. Background The United States Small Business Administration (SBA) helps American small businesses by providing loans and educational services. In 2020, Congress expanded the SBA’s Economic Injury Disaster Loan (EIDL) Program to address the COVID-19 pandemic. Under the expanded EIDL Program, a small business could receive grant money based on the number of people it employed—more employees meant more funds. Similarly, a business could also receive loan money based on a formula tied to gross revenue. No. 25-3061, United States v. Alexander Because of the urgent need to fund businesses during the pandemic, the EIDL Program streamlined the application process for grants and loans. To determine eligibility, the Program relied on credit checks, bank account verifications, and applicant representations. In 2006, Alexander obtained a cosmetology license and began work as a hairstylist, renting booths at various barbershops. For 2019, Alexander reported gross sales of $33,841. In addition to providing hairstyling services, Alexander owned an LLC, TressD, which sold hair bundles and wigs. For all relevant years, TressD did not file taxes, and there is no evidence that the business had employees. In 2020, Alexander submitted a loan application to the SBA. In the application, she listed her name as the business and reported $125,000 in gross revenue for the 12 months preceding the pandemic. Additionally, she reported employing 10 individuals. Minutes after submitting the first application, Alexander submitted a second application using her daughter’s name as the business. She claimed that the business had a gross revenue of $120,000 and that it employed ten individuals. The next day, Alexander submitted a third application under her LLC, TressD, and indicated a gross income of $175,000 and employment of 15 individuals. Subsequently, Alexander received three disbursements from the SBA: a $10,000 grant for the first application, a $10,000 grant for the second, and a $71,000 loan for the third. To receive the loan, Alexander agreed that the loan proceeds were for alleviating COVID-19 related economic injury, certified that no one was paid in connection with her application, and represented that the information she provided was true with warnings that she could face criminal sanction and penalty of perjury