United States v. Miller, No. 17-10594 (5th Cir. 2018)
Annotate this CaseThe Fifth Circuit affirmed defendant's sentence after she pleaded guilty without a plea agreement to bank fraud. The court held that the district court did not clearly err by applying a two-level enhancement under USSG 3B1.3 for abusing a position of trust where she was the accounts payable clerk for her company and used her position to significantly commission and conceal her fraudulent scheme. The court also held that the district court did not clearly err by applying a two-level enhancement under USSG 2B1.1(b)(10)(C) for using sophisticated means where defendant employed multiple methods that made it more difficult to detect her bank fraud.
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