221106P.pdf   10/11/2023  United States  v.  Arondo Harris
   U.S. Court of Appeals Case No:  22-1106
                          and No:  22-2368
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Stras, Author, with Smith, Chief Judge, and Kobes, Circuit 
   Judge] 
   Criminal case - Criminal law and sentencing. Defendant's actions in this 
   fraud case affected interstate commerce, and he was properly convicted 
   under 18 U.S.C. Sec. 1028(c)(3)(A); the prosecution's closing arguments 
   did not require reversal under plain error analysis, as the statements 
   were either within the bounds of proper closing argument, or, assuming 
   they were not, they did not affect defendant's substantial rights; claim 
   of ineffective assistance of counsel rejected; with respect to defendant's 
   sentence, the value of the loss was not a reasonable estimate, and on 
   remand, the district court should adopt a reasonable estimate of the fair 
   market value at the time the properties in question were transferred, 
   either by using a measure that reflects the value at that point, or by 
   accounting for defendant's post-fraud improvements and market value 
   changes during the intervening period.