The Fourth Circuit Court of Appeals upheld the conviction and sentencing of Rojay Lawson, a South Carolina-based participant in a Jamaican-run telemarketing fraud scheme that targeted elderly individuals across the United States. The scam, which operated between 2016 and 2020, defrauded at least 179 victims, most of whom were over the age of 65, of more than $720,000 through a fraudulent sweepstakes operation. Lawson served as a financial intermediary, collecting illicit proceeds, laundering funds, and forwarding money to co-conspirators in Jamaica while taking a 10-20% cut of the funds himself. After pleading guilty to multiple counts of wire fraud, mail fraud, and money laundering conspiracy, Lawson appealed his 78-month federal sentence, arguing that the district court erred in applying sentencing enhancements for targeting vulnerable victims, refusing to grant him a minor role reduction, and improperly calculating the loss amount. The Fourth Circuit rejected these arguments and affirmed his sentence.
The Fraudulent Scheme and Lawson’s Role
Lawson, along with his mother Theresa Lawson, participated in an extensive telemarketing fraud that preyed on elderly individuals across the United States. The scheme originated from Jamaican-based scammers who cold-called victims, falsely informing them that they had won a large sum of money, a new car, or other valuable prizes. To claim their winnings, victims were instructed to pay upfront fees and taxes, which they sent through money orders, wire transfers, prepaid debit cards, and personal checks to addresses in South Carolina controlled by the Lawsons.
Once the money arrived, Lawson and his mother laundered the funds through multiple bank accounts, including some fraudulently opened in victims’ names. They retained a portion of the proceeds for themselves and transferred the remainder back to their co-conspirators in Jamaica. The average age of the victims was 75, with some being scammed out of their life savings. Victim statements revealed the devastating impact of the fraud:
- A 91-year-old woman was scammed out of $27,000.
- An 85-year-old man lost $50,000 to the scheme.
- Victims were repeatedly targeted (“reloaded”), meaning once they fell for the scam, they were contacted again and persuaded to send additional money.
A grand jury indicted Lawson and his mother in 2020, charging them with sixteen counts, including conspiracy to commit wire fraud, multiple counts of substantive wire and mail fraud, and conspiracy to commit money laundering. Lawson pleaded guilty to 13 counts while disputing his involvement before arriving in the United States in 2017.
Sentencing and Key Legal Issues on Appeal
At sentencing, the district court determined that:
- Lawson played an integral role in the fraud and was not a minor participant.
- The victims were uniquely vulnerable, justifying a 2-level sentencing enhancement.
- The total loss amount was $720,948, leading to a 14-level enhancement.
Lawson appealed on three primary grounds:
Vulnerable Victim Enhancement
Lawson challenged the application of a 2-level enhancement for targeting vulnerable victims. He argued that old age alone does not automatically render someone vulnerable and that he had no direct contact with the victims, so he could not have known their specific vulnerabilities.
The Fourth Circuit rejected this argument, citing:
The scheme specifically targeted elderly individuals, as acknowledged in Lawson’s guilty plea. Lawson admitted in a post-arrest interview that he knew the victims were elderly. The “Jamaican Lottery Scam” is widely recognized for preying on the elderly, who are more susceptible due to social isolation, cognitive decline, and financial insecurity. Victims’ statements confirmed their vulnerability, such as an 83-year-old victim who sent repeated payments after being deceived by a friendly-sounding scammer. The court emphasized that targeting elderly victims in a telemarketing scam is precisely the type of crime for which the vulnerable victim enhancement applies.
Denial of Minor Role Reduction
Lawson sought a 2-level sentence reduction under U.S.S.G. § 3B1.2, arguing that he was merely a “conduit of funds” with no decision-making authority and thus less culpable than his co-conspirators in Jamaica.
The Fourth Circuit disagreed, holding that:
- Lawson was essential to the fraud because he managed, stored, and laundered the stolen money, enabling the scam to continue.
- He and his mother were directly responsible for distributing at least $720,948 to Jamaican conspirators.
He actively recruited his mother into the scheme while still in Jamaica. - He personally profited, keeping up to 20% of the illicit proceeds.
The court found that Lawson was not substantially less culpable than the average participant in the conspiracy and was therefore not entitled to a minor role reduction.
Loss Calculation and Restitution
Lawson challenged the loss calculation, claiming that the court improperly combined “intended” and “actual” losses, inflating his sentence. The Fourth Circuit rejected this argument, explaining that:
- The full $720,948 loss was both actual and intended, as victims actually sent that amount and Lawson purposely sought to defraud them.
- There was no evidence that Lawson’s intended loss exceeded actual losses or that he was held accountable for any amount he did not personally launder.
- The loss amount was supported by detailed bank and mail records, which tracked fraudulent transactions.
The court also upheld the $405,401 restitution order, which covered losses to identified victims and was jointly imposed on Lawson and his mother.
Final Ruling and Significance
The Fourth Circuit unanimously affirmed Lawson’s 78-month prison sentence, finding that the district court properly applied sentencing enhancements based on the scheme’s targeting of elderly victims.
Lawson’s role was integral to the fraud, disqualifying him from a sentence reduction. The loss calculation was accurate, and restitution was appropriately ordered.
The decision underscores the harsh penalties for fraud schemes targeting elderly victims, particularly when defendants attempt to minimize their role or contest well-established sentencing guidelines. The ruling serves as a strong deterrent against international telemarketing scams, reinforcing that courts will hold all participants—regardless of their geographic location—accountable for their role in perpetuating financial exploitation.
Source: United States v. Lawson, 2025 U.S. App. LEXIS 2878.