State v. Ross, 659 N.W.2d 122 (Wis. Ct. App. 2002)

Cases | State v. Ross, 659 N.W.2d 122 (Wis. Ct. App. 2002) | 2018

A jury found the defendant guilty of numerous crimes related to the fraudulent sale of securities. The defendant was ordered, among other things, to pay restitution in the amount of $587,100 to the victims of his crimes. The defendant appealed the restitution order, arguing that there was no causal nexus between the losses to investors and his criminal activity, and that part of the restitution represented sales transactions that occurred outside of Wisconsin, and were, therefore, not subject to the court’s jurisdiction. The Court of Appeals of Wisconsin, District One, affirmed the judgment of the trial court, noting that the victims in this case invested in the defendant’s enterprise because of the defendant’s fraud and lack of full disclosure. Thus, there was a nexus between the defendant’s crimes and the victims’ losses. Furthermore, the defendant was convicted of a pattern of racketeering, which had its basis in fraudulent activities occurring in Wisconsin. The defendant’s fraudulent activities in Wisconsin were a substantial factor in attracting investors in other states. Thus, there was also a nexus between the defendant’s crimes and losses to victims outside of Wisconsin.