United States v. Sandra Bart

MURPHY, Circuit Judge.

After a five day trial, a jury found Sandra Bart guilty of conspiracy to commit visa fraud, 18 U.S.C. § 371 ; conspiracy to commit fraud in foreign labor contracting, 18 U.S.C. § 1349 ; and conspiracy to commit mail and wire fraud, 18 U.S.C. § 1349 . Bart's convictions arise from her role in a scheme to bring seasonal workers to the United States through federal work visa programs and then require them to pay a recruitment fee, travel costs, and kickbacks on their wages. Bart appeals, claiming that the jury verdict was not supported by sufficient evidence and that the…