United States of America v. Rohan Lyttle

PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
____________
No. 24-3207
____________
UNITED STATES OF AMERICA
v.
ROHAN LYTTLE
Appellant
____________
On Appeal from the United States District Court
for the Middle District of Pennsylvania
(D.C. No. 1:21-cr-00026-002)
District Judge: Honorable Christopher C. Conner
____________
Submitted Under Third Circuit L.A.R. 34.1(a)
February 6, 2026
Before: HARDIMAN, MONTGOMERY-REEVES, and ROTH,
Circuit Judges
(Filed: March 16, 2026)
____________
OPINION OF THE COURT
____________

-- 1 of 15 --

2
HARDIMAN, Circuit Judge.
Rohan Lyttle, a native of Jamaica residing in New York,
managed a scam that defrauded at least eight elderly victims.
It was a family affair that included Lyttle’s ex-wife, Caron
Pitter, his son, Rohan Lyttle, Jr., and his former paramour and
Junior’s mother, Charlene Marshall. After Lyttle was
convicted on all counts charged against him, he filed this
appeal. Unpersuaded by any of Lyttle’s arguments, we will
affirm his judgment.
I
Lyttle was charged with conspiracy to commit wire
fraud and mail fraud, in violation of 18 U.S.C. § 1349 (Count
1); mail fraud, in violation of 18 U.S.C. § 1341 (Counts 5 and
6); wire fraud, in violation of 18 U.S.C. § 1343 (Count 7);
transportation of goods taken by fraud, in violation of 18
U.S.C. § 2314 (Count 8); and conspiracy to launder monetary
instruments, in violation of 18 U.S.C. § 1956(h) (Count 9).
After a nine-day jury trial, he was convicted on all counts.
The scheme was facilitated by several businesses Lyttle
owned in Queens, New York and Kingston, Jamaica. Lyttle
and Pitter operated Ro-Cars Auto, an auto body shop, in New
York. Lyttle also had ties to RWR Collision, a towing
company, and Work Hard Motors, an entity that was used to
purchase salvaged vehicles. Meanwhile, Junior and Marshall
operated Rolcam Company Limited, a used car dealership, in
Jamaica. Ro-Cars purchased vehicles in New York and fixed
them up before shipping them to Jamaica for resale by Rolcam.
The evidence at trial established that these businesses
were used to launder money acquired through an advance-fee

-- 2 of 15 --

3
lottery scam that targeted elderly Americans. The scam
revolved around an unidentified individual posing as “Andrew
Goldberg,” the former CEO of Publishers Clearing House.
“Goldberg” contacted seniors, falsely claiming that they had
won large sums in a Publishers Clearing House sweepstakes.
But there was a catch: to receive their “prize money,” the
victims were told they had to prepay certain taxes and fees.
Victims withdrew large sums of money from bank
accounts, insurance policies, and retirement plans to obtain
their “prize money.” “Goldberg” instructed victims to mail
cash, wire money, or even purchase and ship car parts to the
Defendants’ homes and businesses in New York. After a report
from a victim’s family brought the scam to the attention of law
enforcement, the United States Postal Inspection Service
identified a network of individuals who had sent and received
packages at the direction of “Goldberg.” Lyttle, Marshall,
Pitter, and Junior were indicted. The first three were tried and
convicted; Junior remains a fugitive.
One of the victims, Thomas Trouton, testified that
“Goldberg” informed him he had won prize money and a
Range Rover. Before receiving the vehicle, “Goldberg”
instructed Trouton to purchase and mail thousands of dollars
of parts that the vehicle needed for repairs. Trouton purchased
over $15,000 in parts in two separate credit card transactions
at a Range Rover dealership in Harrisburg, Pennsylvania. His
understanding was that the parts were “supposed to be sent to
Ro-Cars Auto in New York [for repair] and that Land Rover
would arrange for pickup and delivery” of his car. App. II 198.
Days after making the purchases, Trouton called Ro-Cars in
New York to confirm they had received the shipment. He
spoke to someone there who told him that the parts had been
received. Trouton had also mailed packages containing

-- 3 of 15 --

4
thousands of dollars in cash to addresses associated with Lyttle
and his co-Defendants, including Marshall’s residence (though
the package was addressed to Pitter) and Ro-Cars’s address in
New York. Trouton never received a Range Rover.
The evidence showed that Lyttle received hundreds of
thousands of dollars from the victims. At the direction of
“Goldberg,” multiple shipments (typically bundles of cash)
were sent to several of the Defendants’ homes and businesses
in New York. For example, in 2017, another elderly victim, a
South Carolina resident with no connection to Ro-Cars, wired
approximately $16,500 to its business bank account. In 2020—
at the height of the Defendants’ involvement in the scam—
another out-of-state victim mailed several packages of cash to
Ro-Cars.
After the cash arrived, Lyttle, Pitter, or Marshall would
launder that money through either personal bank accounts or
business accounts related to Lyttle’s entities. For instance,
Pitter and Marshall regularly made bulk cash deposits (often
immediately after a package was delivered) into different bank
accounts. They would structure the transactions in small
increments by making multiple cash deposits at different
ATMs on the same day. A litigation finance expert testified
that, from 2019 to 2020, Pitter’s transactions alone totaled over
$300,000, consisting mostly of ATM cash deposits and the
purchase of cashier’s checks.
In addition, a forensic examination of a desktop
computer from Ro-Cars’s office showed that, on or about
January 24, 2020, a series of YouTube videos about Jamaican
lottery scams were viewed on the device. An email account in
the name of David Hunt was signed into the computer.
Evidence at trial showed that Lyttle had used the pseudonym

-- 4 of 15 --

5
“David Hunt” in the past. One of these videos was a short clip
from a 2013 news report about Jamaica-based advance-fee
lottery scams.
Before trial, all Defendants moved to exclude the video
from evidence. They argued that the video was irrelevant and,
alternatively, that it should be excluded because its prejudicial
effect substantially outweighed any probative value under Rule
403 of the Federal Rules of Evidence. The District Court
entered a small portion of the video into evidence as Exhibit
220 only to show “Lyttle’s purported knowledge of its contents
and intent to undertake a fraudulent scheme himself.” App. I
40–41. The entire video was nearly seven minutes long, but the
Court permitted only a 63-second portion that discussed
Jamaica-based advance-fee lottery scams generally, including
that those scams often target the elderly. The Court also gave a
limiting instruction, emphasizing that the evidence was
“admitted only to show that whoever accessed the video may
have had the knowledge of or familiarity with a lottery scam.”
App. II 655. It directed jurors not to “use the YouTube video
as evidence of wrongdoing itself or for the truth of the matter
asserted in the video.” App. II 655.
Along with Exhibit 220, Lyttle and his co-Defendants
also objected to the admission of Exhibit 369. That exhibit was
a summary of the Ro-Cars office computer’s browser history,
which included the names of three other videos related to
different types of scams. The Defendants argued that the
exhibit was neither relevant nor admissible under Rule 403.
Again, the Court disagreed.
According to the District Court, Exhibit 369 was
relevant because “it [went] to knowledge, state of mind, [and]
control.” App. II 684. The Court explained that the exhibit

-- 5 of 15 --

6
“place[d] in context the individual who logged in as David
Hunt[]” and “what was viewed” by that person. Id. The Court
was not concerned by the evidence’s alleged prejudicial effect:
“[t]he videos that are identified are not going to be shown” and
the jury had “already seen the [video] that is most poignantly
relevant to the facts of this case,” Exhibit 220. Id. So the
District Court overruled the objection.
At the close of the Government’s case-in-chief, Lyttle
moved for a judgment of acquittal under Rule 29 of the Federal
Rules of Criminal Procedure. Lyttle’s objection was vague. He
“believe[d] the evidence [was] insufficient to establish guilt
beyond a reasonable doubt of the charged offenses,” but
offered no reasons why the District Court should grant the
motion. App. II 1494. Nor did he point to any elements of the
charged offenses for which the evidence was purportedly
insufficient. In denying Lyttle’s motion, the Court detailed
why, in its view, there was sufficient evidence to support a
conviction on each count of the indictment.
As for Count 7 (wire fraud), the District Court noted that
the parties had stipulated that Trouton’s two credit card
purchases were wire transactions under 18 U.S.C. § 1343. The
Court reasoned that “the jury could conclude that Mr. Lyttle
was aware of Andrew Goldberg’s directions to Mr. Trouton
and acted in furtherance of [the] wire fraud by receiving the
auto parts.” App. II 1508. Because Lyttle accepted over
$15,000 of luxury vehicle parts from Trouton—an out-of-state
resident who had never been a customer of his shop—the Court
determined that there was sufficient evidence to support the
guilty verdict on Count 7. Lyttle did not argue that Trouton’s
use of a credit card (rather than cash) was not reasonably
foreseeable—the argument he now raises on appeal—at any
point before, during, or after the trial. The District Court—

-- 6 of 15 --

7
despite walking through each count and its reasons why the
evidence was sufficient to sustain a conviction on each—thus
did not have an opportunity to address the argument Lyttle
raises now.
After the jury rendered its guilty verdict on all counts,
the District Court sentenced Lyttle to 97 months’
imprisonment, followed by a 3-year term of supervised release.
It also ordered Lyttle to pay restitution in the amount of
$245,148. At sentencing, the District Court applied a three-
level enhancement under § 3B1.1(b) of the United States
Sentencing Guidelines for Lyttle’s role as a “manager or
supervisor” of five or more participants in the criminal activity.
He noted that there were at least five participants—the four
indicted (Lyttle, Junior, Marshall, and Pitter) along with the
unidentified individual posing as “Goldberg.”
Lyttle owned and operated Ro-Cars Auto (and its
related entities) alongside his co-Defendants. According to the
District Court, the evidence at trial established that Lyttle had
educated Pitter, Marshall, and Junior on “the purpose of each
business entity and how they should operate each business to
maximize cash flow and profits.” S. App. 21. Lyttle also
“carefully delegated tasks and authority for his business
entities to perpetuate the fraud.” Id. The Court concluded that
“Lyttle was a manager or supervisor in the offense conduct”
because, even though “Goldberg” was the putative ringleader
of the scheme, Lyttle “was [an] individual who directed others
to undertake activity in furtherance of the frauds that are the
subject of the offenses of conviction.” S. App. 23. For example,
Lyttle allowed Pitter to sign for cash packages at Ro-Cars and
“enabled [] Pitter and [] Marshall to launder victims’ funds by
moving money between bank accounts and by purchasing
cashier’s checks and used cars for his business.” S. App. 21.

-- 7 of 15 --

8
Lyttle appeals his judgment of conviction and his
sentence, arguing that: (1) the District Court erred in denying
his Rule 29 motion; (2) the Court erroneously applied a
managerial enhancement to his sentence under Guidelines
§ 3B1.1(b); and (3) the Court abused its discretion by
admitting two exhibits into evidence in violation of Rules 401
and 403 of the Federal Rules of Evidence.
II1
Lyttle first contends that the evidence was insufficient
to maintain his wire fraud conviction on Count 7 under 18
U.S.C. § 1343. He argues it was not reasonably foreseeable
that Trouton, one of his victims, would use a credit card to
purchase auto parts in Pennsylvania and mail them to Ro-Cars
in New York. Lyttle maintains that he could not have
reasonably foreseen Trouton’s use of a credit card to make the
purchases because “Goldberg” routinely instructed victims to
pay in cash, Lyttle ran a mostly cash business, and “the order
form Goldberg sent to Mr. Trouton indicated that the terms of
payment were to be cash.” Lyttle Br. 6.
Lyttle never made that argument in the District Court,
so we review it now for plain error. See United States v.
Abrams, 165 F.4th 784, 801 (3d Cir. 2026); United States v.
Williams, 974 F.3d 320, 361 (3d Cir. 2020). When Lyttle
moved for acquittal on this count under Rule 29, he raised only
a general objection, invoking Rule 29 without providing any
specific argument to support it:
1 The District Court had jurisdiction under 18 U.S.C. § 3231.
We have jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C.
§ 3742(A).

-- 8 of 15 --

9
If it pleases the court, we likewise make a motion for
judgment of acquittal pursuant to Rule 29 of the Federal
Rules of Criminal Procedure because we believe the
evidence is insufficient to establish guilt beyond a
reasonable doubt of the charged offenses in the
indictment against Mr. Lyttle.
App. II 1494.
This vague objection mentioned neither which count(s)
of the indictment it related to nor any specific reasons why the
District Court should have granted the motion. So Lyttle did
not preserve the argument he now raises on appeal. See
Abrams, 165 F.4th at 801. But even had he done so, we detect
no error—much less plain error—in the District Court’s denial
of the Rule 29 motion.
To prove wire fraud, the Government had to show:
“(1) the defendant’s knowing and willful participation in a
scheme or artifice to defraud[;] (2) with the specific intent to
defraud[;] and (3) the use of interstate wire communications in
furtherance of the scheme.” United States v. Andrews, 681 F.3d
509, 528 (3d Cir. 2012) (citation modified). If the defendant
should “reasonably have foreseen” use of the interstate wire
communication, the defendant will be deemed to have used
“interstate wires” within the meaning of the statute—even if he
did not personally send the wire or instruct someone else to do
so. United States v. Bentz, 21 F.3d 37, 40 (3d Cir. 1994).
When a defendant argues that the evidence was
insufficient to support a jury verdict, “[w]e must view the
evidence in the light most favorable to the government and
must sustain [the] jury’s verdict if ‘a reasonable jury believing
the government’s evidence could find beyond a reasonable

-- 9 of 15 --

10
doubt that the government proved all the elements of the
offense.’” United States v. Pressler, 256 F.3d 144, 149 (3d Cir.
2001) (citation omitted). “[O]nly when the record contains no
evidence, regardless of how it is weighted, from which the jury
could find guilt beyond a reasonable doubt, may an appellate
court overturn the verdict.” United States v. Anderson, 108
F.3d 478, 481 (3d Cir. 1997) (citation modified).
Here, viewing the evidence in the light most favorable
to the Government, we hold that a rational jury could have
concluded that the wire in question was reasonably
foreseeable. There is ample evidence in the record that Lyttle
accepted delivery of the auto parts Trouton purchased in
Pennsylvania and that the Range Rover promised to Trouton
was ultimately repaired and shipped to Jamaica. So Lyttle had
knowledge of the purchases. And regardless of “Goldberg’s”
purported preference for cash or Ro-Cars’s status as a cash-
based business, the record also supports the conclusion that
Lyttle should have reasonably foreseen that a purchaser of over
$15,000 in auto parts might use a credit card to purchase them.
This is especially true given that large purchases are typically
made through electronic forms of payment.
III
Lyttle also argues that the District Court erred at
sentencing by imposing a three-level offense enhancement
under § 3B1.1(b) of the Sentencing Guidelines because he was
a manager or supervisor of criminal activity involving five or
more participants. Lyttle acknowledged that he was the
supervisor of his businesses’ legitimate activity but argued that
there was no evidence he supervised the criminal activity
charged in the indictment.

-- 10 of 15 --

11
Because the “interpretation of the [Guidelines] is a legal
question,” and Lyttle preserved this argument by raising it at
sentencing, we exercise plenary review over the meaning of
§ 3B1.1(b). United States v. Nasir, 17 F.4th 459, 468 (3d Cir.
2021) (en banc). But we review the District Court’s factual
findings for clear error. See United States v. DeGovanni, 104
F.3d 43, 44 (3d Cir. 1997).
The question here is whether the District Court correctly
determined that Lyttle was a “manager or supervisor” of the
criminal activity. See DeGovanni, 104 F.3d at 46 (“[A]
defendant’s role in the criminal activity is the operative issue”
for purposes of § 3B1.1). We hold it did.
A “manager or supervisor” within the meaning of
Guidelines § 3B1.1 is someone who “exercise[s] some degree
of control over” others involved in the offense. United States
v. Raia, 993 F.3d 185, 192 (3d Cir. 2021) (quoting United
States v. Fountain, 792 F.3d 310, 321 (3d Cir. 2015)). In
United States v. Adair, we addressed § 3B1.1(a), which
provides for a four-level increase if the defendant was an
“organizer or leader of a criminal activity that involved five or
more participants or was otherwise extensive.” 38 F.4th 341,
347–55 (3d Cir. 2022). We reasoned that, because § 3B1.1’s
structure provided greater penalties for “organizers” and
“leaders” than the “managers” and “supervisors” in subsection
(b), “organizers” and “leaders” must have “greater culpability
than managers or supervisors.” Adair, 38 F.4th at 352. After
assessing the ordinary meaning of the text in context with the
provision’s structure, purpose, and history, we concluded that
“an ‘organizer’ is a person who generates a coherent functional
structure for coordinated criminal activity” and “a ‘leader’ is a
person with high-level directive power or influence over
criminal activity.” Id. at 354. Relying on contemporary

-- 11 of 15 --

12
definitions, we noted in dicta that the terms “manager” and
“supervisor” referred to “a person with oversight over
operations or other persons.” Id. at 352 nn.16–17. We agree
that “manager” or “supervisor” is a step down from “organizer
or leader,” so the individual who receives the § 3B1.1(b)
enhancement will often be a mid-level member of a criminal
group with at least “some degree of control.” Raia, 993 F.3d at
192 (emphasis added).
The District Court made several relevant factual
findings in applying this managerial sentencing enhancement.
The Court noted that video evidence established that Lyttle
educated Pitter, Marshall, and Junior on “the purpose of each
business entity and how they should operate each business to
maximize cash flow and profits.” S. App. 21. It also found that
Lyttle “carefully delegated tasks and authority” for his
businesses to each of his co-Defendants to “perpetuate the
fraud.” Id. Perceiving no clear error in those factual
determinations, we agree that Lyttle exercised a degree of
control and oversight over Pitter, Marshall, and Junior in the
money laundering operation that led to their indictment and
conviction. Because the District Court properly interpreted and
applied § 3B1.1(b), Lyttle’s sentencing argument fails.
Our decision does not mean that any time a defendant is
the manager or supervisor of a legitimate business and is
subsequently charged in relation to activities related to the
business that he will necessarily be a “manager or supervisor”
within the meaning of § 3B1.1(b). We hold only that the
evidence here showed Lyttle managed and supervised the
charged criminal activity (money laundering). So the
enhancement applied.

-- 12 of 15 --

13
IV
Finally, Lyttle contends that the District Court violated
Rule 403 of the Federal Rules of Evidence when it admitted
Exhibits 220 and 369 into evidence. We review the District
Court’s evidentiary rulings for abuse of discretion, United
States v. Green, 617 F.3d 233, 239 (3d Cir. 2010), and construe
that discretion “especially broadly” in the Rule 403 context,
United States v. Scarfo, 41 F.4th 136, 178 n.35 (3d Cir. 2022).
“When a court engages in a Rule 403 balancing and articulates
on the record a rational explanation, we will rarely disturb its
ruling.” United States v. Sampson, 980 F.2d 883, 889 (3d Cir.
1992).
Exhibit 220 is a 2013 news clip discussing Jamaica-
based lottery scams targeting elderly Americans. It was viewed
by someone in the Ro-Cars office signed in as “David Hunt”
in January 2020. Lyttle argues that the portions of the video
shown to the jury were “designed to elicit strong emotional
responses” because the report focused on elderly Americans as
victims of Jamaica-based scammers and the chyron included
the phrase “Cruel Fraud.” Lyttle Br. 25.
We do not agree with Lyttle that the video’s probative
value—to show that the person who viewed this video may
have known how these types of scams generally worked—was
substantially outweighed by any of the concerns addressed by
Rule 403. See Fed. R. Evid. 403. Lyttle had used the alias
“David Hunt” in the past and he had access to the computer.
Moreover, the video would imbue the person viewing it with
knowledge of advance-fee lottery scams.
The District Court also gave a proper limiting
instruction. The Court instructed jurors to consider the video

-- 13 of 15 --

14
only to determine whether the individual who viewed it was
generally familiar with this type of scam, not as evidence of
wrongdoing. The Court also curtailed the scope of the video
that was played to the jury. Far from abusing its discretion, it
“reasonably assessed the video[’s] relevance and probative
value and took appropriate steps to mitigate [its] prejudicial
impact.” United States v. Duka, 671 F.3d 329, 351 (3d Cir.
2011); see also id. at 352 (holding that the district court did not
abuse its discretion when it entered violent jihadist training
videos into evidence in a sanitized form to show the
defendants’ state of mind in planning an attack on the United
States).
For substantially the same reasons, the admission of
Exhibit 369—which was merely a list of the titles of similar
videos from the computer’s browsing history (with several
redactions)—was not an abuse of discretion. Exhibit 369 had
similar probative value as Exhibit 220 and, because it involved
mere titles rather than an evocative video describing scams, its
effect was more muted than Exhibit 220. Because the District
Court did not abuse its discretion in admitting either exhibit,
Lyttle’s evidentiary argument fails.2
***
2 Lyttle also argues that Exhibits 220 and 369 were irrelevant
under Rule 401 of the Federal Rules of Evidence. But that
argument fails as well. Rule 401 is not a “high standard.”
Hurley v. Atl. City Police Dep’t, 174 F.3d 95, 109–10 (3d Cir.
1999). Because both exhibits made it more likely that the
viewer of the video had knowledge of advance-fee lottery
scams—a material fact—the evidence was relevant.

-- 14 of 15 --

15
For the stated reasons, we will affirm the judgment.
Robert J. Daniels
Zachary A. Toland
Killian & Gephart
Counsel for Appellant
Jeffery F. St. John
Carlo D. Marchioli
Office of United States Attorney
Middle District of Pennsylvania
Counsel for Appellee

-- 15 of 15 --