United States v. Thompson, No. 14-2267 (2d Cir. 2015)
Annotate this CaseDefendant Thompson appealed his sentence for drug-related convictions. The court concluded that the district court cannot satisfy United States v. Dunnigan by simply adopting a PSR's conclusory statements that the defendant committed perjury. Rather, the court has allowed a district court to rely on the PSR to impose an obstruction‐of‐justice enhancement only if the PSR “sets forth reasonably detailed findings in support of its conclusions.” In this case, the district court did not make a finding of specific intent to obstruct justice before imposing a two-level sentencing enhancement for obstruction of justice. The court concluded that this error is not harmless because the record does not clearly indicate that the district court would have imposed the same sentence in any event. The court vacated as to this issue and remanded for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.