Georgia Used-Car Dealer Sentenced for $3 Million Floor-Plan Fraud Scheme

Mitchell C. Simpson, a used-car dealer from Cornelia, Georgia, has been sentenced to federal prison for wire fraud after defrauding three financial companies of over $3 million through a deceptive financing scheme. U.S. District Judge Steve C. Jones sentenced Simpson, 56, to three years and five months in prison, followed by three years of supervised release, and ordered him to pay $105,803.70 in restitution.

From 2012 to 2019, Simpson operated Mitch Simpson Motors, a Cleveland, Georgia, dealership that relied on floor-plan financing from three lenders: Dealer Financial Holdings LLC, Americash Advance, Inc., and Floorplan Xpress, LLC-OK. The financing allowed Simpson to maintain an inventory of vehicles under contracts that required him to report truthful and complete information about the financed vehicles. Simpson exploited this trust by using vehicles as collateral for multiple loans—known as double and triple floor-planning—and by failing to inform the lenders about other liens, misleading them to secure additional funding.

Additionally, Simpson withheld funds owed to lenders after selling vehicles in which they held security interests, instead moving titles around in a tactic referred to as “out of trust,” violating the terms of his financing agreements. His actions left the floor-plan lenders with significant financial losses.

U.S. Attorney Ryan K. Buchanan emphasized that Simpson abused his position of trust, impacting the companies that supported his business operations. FBI Atlanta Senior Supervisory Resident Agent Mitchell Jackson underscored the importance of partnerships in holding offenders accountable and securing justice for victims.

Simpson pleaded guilty to wire fraud on July 2, 2024. The FBI conducted the investigation, with Assistant U.S. Attorney John Russell Phillips and former Assistant U.S. Attorney David A. O’Neal prosecuting the case.