Defendants appealed on numerous grounds, including on the ground that the US District Court for the Southern District of Florida erred in admitting evidence in violation of the Federal Rules of Evidence. The Eleventh Circuit found that, while there may have been a question about whether the district court abused its discretion in admitting such evidence, any error was harmless as the record provided “overwhelming evidence of defendants’ fraud.” Therefore, the court affirmed the defendants’ convictions and sentences.   

US v. Curshen, et al., Nos. 12-12658, 12-12659 (11th Cir. May 28, 2014).