United States v. Page: Revoked Tax-Exempt Status and Misleading Nonprofit Fundraising

Case Overview and Legal Framework

In United States v. Page, No. 24-3871 (6th Cir. Dec. 30, 2025), the United States Court of Appeals for the Sixth Circuit affirmed the criminal conviction and sentence of Sir Maejor Page for wire fraud and money laundering. The published decision, spanning twenty printed pages, addresses sufficiency of evidence, trial evidentiary rulings, character evidence restrictions, and federal sentencing guidelines enhancements arising from a fraudulent social media fundraising scheme.

It is critical to distinguish the legal posture of this case: United States v. Page is a federal criminal prosecution under Title 18 of the United States Code, not a civil tax deficiency or Tax Court determination regarding donor deductibility. The underlying fact pattern involves an organization whose tax-exempt status was automatically revoked by the Internal Revenue Service under Internal Revenue Code Section 6033(j). The decision illustrates how misrepresentations made during public solicitations after an exemption revocation can lead to federal criminal liability. For California practitioners, Sixth Circuit rulings are persuasive non-binding authority, offering instructive guidance on how federal courts analyze fund diversion and fraudulent fundraising representations. This case complements our discussion on nonprofit tax-exempt status revocation and fundraising disclosures.

Factual Background and Procedural Posture

In 2014, Sir Maejor Page founded Black Lives Matter of Greater Atlanta (BLMGA) in Atlanta, Georgia, incorporating the group as a Georgia nonprofit, opening an organizational bank account, and applying for tax-exempt status with the IRS (United States v. Page, No. 24-3871, slip op. at 2 (6th Cir. Dec. 30, 2025)). This tax-exempt status enabled BLMGA to receive donations through Facebook's searchable directory of registered nonprofits.

In 2019, the IRS automatically revoked BLMGA's tax-exempt status under Section 6033(j) after the organization failed to file required annual information returns for three consecutive years (slip op. at 2). Nine months after the revocation, Page notified Facebook from a personal account that BLMGA was no longer tax-exempt and requested the cancellation of fundraisers. When Facebook requested administrative details to process the change, Page failed to respond, leaving BLMGA listed as an active tax-exempt entity on the platform (slip op. at 2).

Between May and September 2020, following widespread national attention surrounding social justice events, over $490,000 in donations flowed into BLMGA's bank account (slip op. at 3). Page pinned a notice to BLMGA's social media page stating the group was no longer registered or tax-exempt, but simultaneously told prospective donors that BLMGA was a grassroots movement using funds for protest equipment, food, legal fees, and bail, explicitly assuring donors that expenditures were strictly for the movement and not personal (slip op. at 3). When users questioned the organization's status, Page publicly clarified that funds could still be sent to support protests in other cities (slip op. at 3).

In reality, Page converted the donated funds for personal use, spending organizational receipts on personal purchases, acquiring firearms after legal advice against using charitable funds for them, and paying over $108,000 to purchase a residential property in Toledo, Ohio, alongside home renovations and furniture (slip op. at 3-4).

In March 2021, a federal grand jury in the Northern District of Ohio indicted Page on one count of wire fraud (18 U.S.C. § 1343) and three counts of money laundering (18 U.S.C. §§ 1956(a)(1)(B)(i), 1957) (slip op. at 4). Following a jury trial before District Judge Jeffrey James Helmick, in which Page testified in his defense, the jury convicted him on all counts (slip op. at 4).

At sentencing, the district court overruled Page's objections to the Presentence Investigation Report, applying enhancements for obstruction of justice based on trial perjury, calculating the loss amount at $490,000, and finding the scheme involved more than ten victims (slip op. at 4-5). The court sentenced Page to a below-Guidelines term of 42 months imprisonment on each count, running concurrently, followed by three years of supervised release (slip op. at 5). Page appealed his convictions and sentence to the Sixth Circuit.

Legal Issues Under Review

The Sixth Circuit addressed four primary legal questions on appeal:

• Whether sufficient evidence supported the jury's verdict convicting Page of wire fraud under 18 U.S.C. § 1343 and money laundering under 18 U.S.C. §§ 1956 and 1957.
• Whether the government's evidence at trial impermissibly varied from the allegations in the indictment.
• Whether the district court abused its discretion or committed plain error in its trial evidentiary rulings under Federal Rules of Evidence 403, 404, 405, and 608(b).
• Whether the district court properly calculated the advisory United States Sentencing Guidelines range regarding obstruction of justice, loss calculation, and victim count.

The Sixth Circuit’s Reasoning

Writing for a unanimous panel that included Circuit Judges Moore and Ritz, Circuit Judge Thapar affirmed the district court's judgment across all issues (slip op. at 1, 20).

Sufficiency of Evidence and Indictment Variance

Because Page failed to renew his Rule 29 motion for judgment of acquittal at the close of all evidence, the Sixth Circuit reviewed his sufficiency challenge under the demanding manifest miscarriage of justice standard, requiring a showing that the record was devoid of evidence pointing to guilt (slip op. at 5).

On the wire fraud count, the court held that Page actively misrepresented to donors how their contributions would be deployed, repeatedly assuring inquiries that donations would fund protest supplies and legal support while spending the proceeds on personal lifestyle expenses (slip op. at 6-7). The court rejected Page's defense that pinned notices regarding lapsed tax-exempt status insulated him, emphasizing that selective tax disclosures did not inform donors that funds would be diverted to personal real estate, custom clothing, or firearms (slip op. at 7). On the money laundering counts under 18 U.S.C. § 1956(a)(1)(B)(i) and § 1957, the court held that the wire fraud scheme was complete when false representations induced donations, rendering the funds criminally derived proceeds at the time of the real estate and furniture transactions (slip op. at 8-10). The court further held that no variance occurred between the indictment and trial evidence because the government proved the precise scheme alleged (slip op. at 10-11).

Evidentiary Rulings

The court upheld evidence of certain personal expenditures as probative of fraudulent intent or knowledge, including firearm purchases after a lawyer’s warning. It separately permitted a truthfulness-related cross-examination under Rule 608(b). These holdings turned on the record and the questions raised; they were not a general license to introduce prejudicial personal conduct. Page, slip op. at 11–14.

Addressing character evidence under Rules 404 and 405, the court held that the government was entitled under Rule 404(a)(2)(A) to offer rebuttal testimony after Page put his good character and community activism in issue (slip op. at 14-15). Although direct testimony from two witnesses regarding specific instances of online conduct violated Rule 405(a)'s limitation to reputation or opinion testimony, the panel concluded under plain error review that the error was harmless given the overwhelming independent evidence of guilt (slip op. at 15-16).

Sentencing Guidelines Calculation

The court affirmed all three challenged sentencing enhancements:

• Obstruction of Justice (U.S.S.G. § 3C1.1): The district court made explicit, supported findings that Page committed trial perjury by falsely testifying under oath that he consulted a lawyer prior to submitting an offer on the Toledo home, a material statement aimed at bolstering his defense regarding intent (slip op. at 16-17).
• Loss Calculation (U.S.S.G. § 2B1.1): Because the fraud scheme was pervasive, the district court properly calculated loss using the full $490,000 gross donations raised, shifting the burden to the defense to prove specific legitimate offsets—a burden Page failed to satisfy (slip op. at 18-19).
• Number of Victims (U.S.S.G. § 2B1.1(b)(2)(A)(i)): The trial record established over 18,000 individual Facebook donors, supporting a reasonable inference that more than ten victims suffered financial loss from the fraudulent misrepresentations (slip op. at 19-20).

Limitations and Persuasive Authority Scope

The holding in United States v. Page is strictly an adjudication of federal criminal fraud and sentencing procedure. It does not establish civil tax standards, interpret internal revenue tax deficiency statutes, or alter donor tax deductibility rules. Furthermore, as a decision from the Sixth Circuit Court of Appeals, its rulings serve as persuasive authority in California federal and state courts, providing guidance on evidentiary balancing and sentencing loss calculations in complex solicitation cases without establishing binding circuit precedent in the Ninth Circuit.

Practical Record Consequences for Nonprofits

The decision in United States v. Page highlights essential compliance and recordkeeping obligations for nonprofit managers and corporate board members:

• Public Solicitations and Duty of Candor: Organizations must ensure that all public solicitations, social media campaign statements, and direct messages accurately reflect both current tax-exempt status and the precise programmatic use of funds.
• Segregation of Corporate Funds: Personal and organizational finances must remain strictly separated. Diverting solicitations to personal accounts or using organizational funds for unapproved personal expenses creates severe criminal exposure under federal fraud statutes.
• Governance and Legal Advice: Boards should maintain written records of legal consultations regarding fund expenditures. Disregarding explicit legal advice against specific transactions can serve as direct evidence of fraudulent intent in federal proceedings.

For additional analysis on establishing proper governance and maintaining compliant organizational records, explore our practice guides on charity insider transfer approval records and IRS and state tax procedure FAQs.