United States v. Wilson, No. 11-2623 (8th Cir. 2012)
Annotate this CaseA jury convicted Appellant of four counts of deprivation of rights and two counts of making false statements. The district court sentenced Appellant to 120 months' imprisonment on the deprivation of rights counts and sixty months' imprisonment on each of the false statements counts, with all terms to be served concurrently. In imposing this sentence, the court applied an enhancement for physical restraint under U.S.S.G. 3A1.3 and an enhancement for aggravated assault resulting in serious bodily injury under U.S.S.G. 2A2.2. On appeal, Appellant challenged the application of the two enhancements. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant moved his victims to an enclosed area to be assaulted, the district court did not err in applying the physical restraint enhancement; and (2) because Appellant had the requisite intent to assault his victims, the district court did not err in applying the enhancement for a crime resulting in serious bodily injury.
Court Description: Criminal case - Sentencing. In a prosecution of a jail administrator for deprivation of rights and making false statements, the district court did not err in imposing sentencing enhancements for physical restraint under Sentencing Guidelines Sec. 3A1.3 and aggravated assault resulting in serious bodily injury under Guidelines Sec. 2A2.2, where the defendant moved the victims to an enclosed area to be assaulted and at least one of the victims suffered serious injuries which required hospitalization.
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