United States v. Shelitha Robertson

── United States v. Shelitha Robertson ── Court: Court of Appeals for the Eleventh Circuit Date: June 05, 2026 Category: NEW USCA11 Case: 24-12557 Document: 53-1 Date Filed: 06/05/2026 Page: 1 of 30 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-12557 ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus SHELITHA RENEE ROBERTSON, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:22-cr-00432-SDG-JEM-1 ____________________ Before ROSENBAUM, BRANCH, and GRANT, Circuit Judges. PER CURIAM: After a trial, Shelitha Robertson was convicted of wire fraud, conspiracy to commit wire fraud, and money laundering. She and USCA11 Case: 24-12557 Document: 53-1 Date Filed: 06/05/2026 Page: 2 of 30 2 Opinion of the Court 24-12557 her co-conspirator, Chandra Norton, submitted fraudulent applica- tions for loans for the Paycheck Protection Program (“PPP”), a COVID-era relief program designed to make it possible for busi- nesses to keep employees on payroll. Robertson and Norton sub- mitted applications for relief claiming that their businesses em- ployed hundreds of people. But in fact, most of the businesses were non-functioning and employed no one. In total, they secured over $14 million in funding before the banks who administered the pro- gram on behalf of the Small Business Administration (“SBA”) de- tected the scheme and froze their accounts. Norton, who was Robertson’s attorney and best friend, ac- cepted a plea deal with prosecutors and was sentenced to 18 months in prison and 3 years of supervised release. At Robertson’s trial, Norton testified that Robertson directed her and encouraged her to submit the applications. A jury found Robertson guilty on all counts, and the judge sentenced her to 87 months in federal prison and three years of supervised release. Robertson now ap- peals, challenging the sufficiency of the evidence, several of the dis- trict court’s evidentiary rulings, and the district court’s sentencing and restitution order. After careful review, we conclude that the evidence to sup- port Robertson’s conviction was sufficient, and the district court did not err in its challenged rulings. Accordingly, we affirm. USCA11 Case: 24-12557 Document: 53-1 Date Filed: 06/05/2026 Page: 3 of 30 24-12557 Opinion of the Court 3 I. Facts and Procedural History1 A grand jury indicted Shelitha Robertson for conspiring with her associate, Chandra Norton, to fraudulently obtain millions of dollars in PPP loans from lending banks, which were guaranteed by the SBA, during the COVID-19 pandemic. 2 The indictment al- leged that Robertson and Norton submitted fraudulent PPP appli- cations for several businesses that Robertson owned, including At- lanta Custom Motors, LLC (“ACM”), the Renee Group, MO Griggs Contracting, Inc. (“Mo Griggs”), and Tritan, Inc. A. Background of the Scheme At the time the scheme began, Norton was an attorney and close associate of Robertson. Robertson, in