TodayLegal News

11th Circuit Affirms 96-Month Bank Fraud Sentence for Alabama Attorney

The U.S. Court of Appeals for the Eleventh Circuit affirmed a 96-month federal sentence for Anna Michelle La Rue, who pleaded guilty to bank fraud while working as an office manager at an Alabama law firm. La Rue had challenged the upward variance from sentencing guidelines as substantively unreasonable.

AI-generated Summary
4 min readcourtlistener
Seal of the Eleventh Circuit Court of Appeals

Case Information

Case No.:
24-13888

Key Takeaways

  • Eleventh Circuit affirmed 96-month sentence for bank fraud committed while working at Alabama law firm
  • Defendant challenged upward variance from guidelines as substantively unreasonable under federal law
  • Court rejected arguments about improper weighing of sentencing factors and sentencing disparities
  • Case involved fraud conduct spanning 2009-2021 while employed as law firm office manager

The U.S. Court of Appeals for the Eleventh Circuit affirmed a 96-month federal prison sentence for Anna Michelle La Rue, who was convicted of bank fraud while employed as an office manager at an Alabama law firm. The decision, filed Jan. 8, 2026, rejected La Rue's arguments that her sentence was substantively unreasonable.

La Rue pleaded guilty to one count of bank fraud in connection with conduct that occurred between 2009 and 2021 while she worked at the Alabama law firm. A federal grand jury had originally indicted her on 10 counts of bank fraud in 2023, but she entered an open plea agreement to one count in exchange for the government dismissing the remaining charges.

The case originated in the U.S. District Court for the Northern District of Alabama, where La Rue received the 96-month sentence that represented an upward variance from the federal sentencing guidelines range. The specific guidelines range was not detailed in the available court documents.

On appeal, La Rue challenged her sentence on multiple grounds, arguing it was substantively unreasonable under federal sentencing standards. She contended that the district court improperly weighed the factors required under 18 U.S.C. § 3553(a), which governs federal sentencing considerations including the nature of the offense, the defendant's history and characteristics, and the need for deterrence and public protection.

La Rue specifically argued that the sentencing court relied too heavily on information that was already incorporated into the sentencing guidelines calculation. She also claimed the court failed to adequately account for mitigating circumstances in her case that should have warranted a lower sentence.

Additionally, La Rue raised concerns about sentencing disparities, arguing that her 96-month sentence created substantial risk of unwarranted disparities when compared with statistical data for other defendants sentenced for similar bank fraud offenses. This type of disparity analysis has become increasingly common in federal appeals as defendants seek to ensure their sentences fall within reasonable ranges compared to similarly situated offenders.

The Eleventh Circuit panel, consisting of Circuit Judges Branch, Luck, and Lagoa, issued a per curiam opinion rejecting these arguments. The court's brief "NOT FOR PUBLICATION" opinion affirmed the district court's sentencing decision after review.

Federal bank fraud carries significant penalties under federal law, with potential sentences of up to 30 years in prison and substantial fines. The offense typically involves schemes to defraud financial institutions or to obtain money or property under the custody or control of banks through false pretenses.

The case reflects ongoing issues in federal sentencing regarding upward variances from guidelines ranges. Since the Supreme Court's decision in *United States v. Booker* (2005), federal sentencing guidelines have been advisory rather than mandatory, giving district courts more discretion in sentencing decisions while requiring consideration of specific statutory factors.

Appellate courts review sentences for reasonableness, examining both procedural and substantive aspects. Procedural reasonableness focuses on whether the court properly calculated the guidelines and considered the § 3553(a) factors, while substantive reasonableness examines whether the sentence is appropriate given all circumstances.

The Eleventh Circuit's affirmance suggests the appeals court found the district court properly considered the required sentencing factors and that the 96-month sentence was within the reasonable range for La Rue's offense conduct and personal circumstances.

While the specific details of La Rue's fraudulent conduct were not fully detailed in the available court documents, bank fraud cases involving law firm employees often involve misappropriation of client funds, unauthorized access to firm accounts, or manipulation of financial records over extended periods.

The case number 24-13888 indicates this was among the criminal appeals docketed in the Eleventh Circuit during 2024, with the district court case originating as 5:23-cr-00048 in the Northern District of Alabama.

La Rue's case adds to the body of Eleventh Circuit precedent on federal sentencing appeals and upward variances. The circuit covers Alabama, Florida, and Georgia, handling numerous federal criminal appeals involving financial crimes.

The affirmance means La Rue's 96-month sentence stands, and she would need to seek further review through a petition for rehearing or potentially the Supreme Court to continue challenging her sentence, though such review would face significant procedural hurdles given the discretionary nature of appellate review of sentencing decisions.

Topics

bank fraudsentencing appealcriminal lawwhite collar crimeembezzlement

Original Source: courtlistener

This AI-generated summary is based on publicly available legal news, court documents, legislation, regulatory filings, and legal developments. For informational purposes only; not legal advice. Read full disclosure →