United States of America v. Adams et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
ANTHONY ADAMS,
Defendant.
2:18-CR-20641-TGB-APP-2
HON. TERRENCE G. BERG
ORDER DENYING
DEFENDANT’S MOTION
FOR BOND
(ECF NOS. 389 & 390)
Presently before the Court is Defendant Anthony Adams’ Motion
for Bond (ECF Nos. 389 & 390) pending sentencing after admitting
responsibility for violating the conditions of his supervised release.
For the foregoing reasons, the Motion will be DENIED.
I. BACKGROUND
On 	September 	20, 	2018, 	Anthony 	Adams 	was 	indicted 	for
conspiracy to commit wire fraud, 18 U.S.C. § 1349, conspiracy to commit
money laundering, § 1956, and several counts of aggravated identity
theft, § 1028A(a)(1). According to the indictment, for nearly three years,
Adams and his coconspirators obtained stolen credit and debit account
information from real, identifiable victims on the dark web and used the
stolen information to purchase more than one million dollars’ worth of
gift cards and Apple iPhones at Walmarts across the country. ECF No. 1.
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Adams committed those acts while under a criminal justice sentence for
credit 	or 	debit 	card 	forgery 	in 	Nevada. 	ECF 	No. 	250 	(sealed),
PageID.1530.
On September 28, 2018, Adams consented to detention pending
trial. ECF No. 23. Adams remained in detention for the entirety of his
pre-trial proceedings, despite filing three motions for bond revocation.1
In July 2019, Adams pleaded guilty to the charges and, in November
2021, he was sentenced to a total of 96 months’ imprisonment followed
by 2 years’ supervised release. ECF No. 274. Adams commenced his
supervised release term on August 23, 2024.
But starting in October 2024, Adams started engaging in similar
criminal 	behavior 	again. 	United 	States 	Probation 	Officer 	Elizabeth
Campana filed a Violation Report and Petition for Warrant on March 5,
2025 charging Adams with eight violations of supervised release, five of
which alleged that he committed new criminal conduct. ECF No. 370. The
1 On November 1, 2018, Defendant filed his first motion for revocation of
his detention order, which the Court denied. ECF No. 76. He filed a
second motion for bond revocation on March 15, 2019. ECF No. 99. The
Court denied the motion after a hearing, because Defendant had not met
his burden to show by clear and convincing evidence that he would not
present a risk of flight or danger to the community if released under 18
U.S.C. § 1343, especially in light of his long history of committing new
crimes while out on supervision. Hearing Tr., ECF No. 184, PageID.966-
67. Defendant filed a third motion for bond on April 23, 2020 in light of
the then-ongoing COVID-19 pandemic, which the Court denied. ECF No.
197.
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report was amended on September 8, 2025 to include two additional
violations. ECF No. 388.
The 	Violation 	Reports 	alleged 	that 	shortly 	after 	his 	release,
between October 10, 2024, and January 16, 2025, Adams improperly and
unlawfully 	obtained 	goods 	from 	home 	improvement 	retail 	stores,
including Lowe’s Home Improvement 	and Home 	Depot, 	by opening
business credit accounts in the names of real victim businesses, using
personally identifiable information of individuals connected to these
businesses, 	without 	those 	individuals 	or 	businesses’ 	knowledge 	or
approval, for his own use and control. ECF Nos. 370 & 388. The Violation
Reports 	also 	alleged 	that 	Adams 	left 	the 	judicial 	district 	without
permission, in violation of his conditions, in October 2024 (Chicago) and
November 2024 (Los Angeles). Id. He also failed to obtain employment or
otherwise 	participate 	in 	any 	educational 	program 	since 	starting
supervised release. Id.
On March 18, 2025, Adams had his initial appearance on the
supervised release violation, and he consented to detention on March 20,
2025. The Court scheduled a supervised release violation hearing for
March 28, 2025 and the parties filed several stipulations to adjourn the
hearing until September 9, 2025. ECF No. 387. On September 9, 2025,
the Court held a hearing on the supervised release violation petition at
which 	Adams 	admitted 	to 	all 	the 	violations. 	He 	was 	subsequently
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indicted for the same criminal conduct. See United States v. Adams, No.
2:25-cr-20668-TGB-APP.
Adams requested during the supervised release violation hearing
that his detention be revoked and that he be released on bond pending
sentencing on December 19, 2025.2 The Government did not object to the
request. The Court took the motion under advisement and allowed
defense counsel to brief the issue. On September 16, 2025, Adams filed a
Motion for Pretrial Release which states that it is not opposed by the
Government. ECF No. 390.
II. LEGAL STANDARD
The standard for release pending sentencing of a supervised release
violation is governed by the 	standard set forth in Federal Rule of
Criminal Procedure 32.1(6) which applies 18 U.S.C. § 3143(a)(1). See
United States v. Phillips, 2024 U.S. Dist. LEXIS 181114, *2-3 (E.D. Mich.
Oct. 2, 2024)(Altman, M.J.). Under § 3143(a)(1), a person who has been
found guilty and who is awaiting imposition of a sentence must be
detained, 	“unless 	the 	judicial 	officer 	finds 	by 	clear 	and 	convincing
evidence that the person is not likely to flee or pose a danger to the safety
of 	any other 	person 	or the 	community 	if released.” 	The 	burden of
establishing by clear and convincing evidence that the defendant will not
2 The parties requested sentencing on the supervised release violation
and the new indictment to be held together. The plea hearing regarding
the new indictment is currently scheduled for November 5, 2025.
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flee or pose a danger to any other person or to the community rests with
the defendant. Fed. R. Crim. P. 32.1(6).
III. DISCUSSION
Adams filed this fifth motion for release (three motions for pre-trial
release in 2018, 2019, and 2020, one motion for sentence reduction in
2022, and the instant motion in 2025) so he can spend time with family
before starting a possibly lengthy prison sentence. Adams argues that he
is not a flight risk given that he has accepted responsibility and has
significant and lifelong ties to the district, namely his parents and
children, including a newborn he has yet to meet. He argues that he is
not a risk of violence because the offenses were non-violent, and that any
concern about continued criminal activity can be mitigated by strict
conditions of supervision, such as home confinement and tether. He also
highlights that the 	Government 	does not object 	to 	release 	pending
sentencing.
While the Court understands Adams’ legitimate desire to spend
time with his family, Adams has not met his burden of showing he would
not be a risk of flight or danger to the community should he be released.
See Fed. R. Crim. P. 32.1(6). In fact, this Court has already thrice found
that Adams would pose a danger to the community or a risk of flight if
released because of his long history of committing new crimes while out
on supervised release. See ECF Nos. 184 & 197.
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Considering Adams’ recent and repeated history of non-compliance
with supervised release conditions, he has failed to show he is likely to
comply with conditions this time around. When seeking a sentence
reduction in 2022, Adams had stated that time in prison had fostered in
him a respect for the law, and that he planned to enroll in vocational
training if released. ECF No. 318, PageID.2562, 2565. But since his
release in August 2024, he has failed to show “respect for the law” as he
has continued to commit wire fraud and identity theft and also violated
his 	conditions 	of 	supervised 	release 	by 	leaving 	the 	judicial 	district
without permission twice. ECF Nos. 370 & 388. He has also failed to
obtain employment or otherwise participate in any educational program,
in violation of his supervised release conditions, despite his alleged
intention to do so upon release. Id.
Thus, 	it 	cannot 	be 	said 	Adams 	has 	been 	“doing 	well 	under
supervision.” See United States v. Hicks, 2024 U.S. Dist. LEXIS 143928,
*2-3 (E.D. Mich. Aug. 13, 2024)(Altman, M.J.) (denying bond despite
noting 	that 	defendant 	“appears 	to 	have 	been 	doing 	well 	under
supervision for the past two years, including getting a job”). Rather,
Adams’ “history of non-compliance while under supervision by engaging
in criminal activity”—more specifically, engaging in the same pattern of
criminal activity as 	his underlying 	and earlier convictions—and by
violating 	his 	conditions 	of 	supervised 	release 	undermine 	Adams’
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argument that strict conditions could mitigate the risk of flight or danger
to the community. See Phillips, 2024 U.S. Dist. LEXIS 181114, *2-3.
Therefore, Adams has failed to show he is not a risk of flight or
danger to the community. See Fed. R. Crim. P. 32.1(6). Given Adams’
repeated 	non-compliance 	with 	supervision 	conditions 	and 	criminal
behavior under supervision, the Court finds Adams is not suitable for
bond pending sentencing. Therefore, Adams’ Motion for Bond (ECF Nos.
389 & 390) is DENIED.
SO ORDERED.
Dated: October 27, 2025 	/s/Terrence G. Berg
TERRENCE G. BERG
UNITED STATES DISTRICT JUDGE
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