United States v. Dowl

Following Hurricane Katrina, Barbara Dowl applied for and received funds from the Government to rebuild a home in New Orleans, Louisiana. However, Dowl did not own the property, and she used the money for non-rebuilding expenditures. The Government charged Dowl with five counts related to this fraud, and a jury found her guilty on all counts. Dowl was sentenced to 69 months’ imprisonment and ordered to pay $156,761 in restitution. On appeal, she challenges both her conviction and sentence. We AFFIRM.

I. BACKGROUND

A. Factual Background

1. The Zimple Street Property

In 1992, Barbara Dowl (“Dowl”)…