U.S. v. Strange, No. 21-2923 (2d Cir. 2023)
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Defendant appealed the district court’s judgment sentencing him to 57 months imprisonment following his plea of guilty to one count of wire fraud. Defendant argued that the district court incorrectly applied a two-level obstruction enhancement and improperly denied him a three-level sentence reduction.
The Second Circuit affirmed. The court held that the district court correctly applied U.S.S.G. Section 3C1.1’s obstruction enhancement to Defendant’s sentence and did not abuse its discretion in denying Defendant U.S.S.G. Section 3E1.1’s acceptance of responsibility reduction. The court explained that at least two of the forged letters satisfy Section 3C1.1’s materiality requirement, which makes the application of the obstruction enhancement proper. In deciding whether to apply the sentence reduction, a district court considers factors such as the defendant’s “voluntary termination or withdrawal from criminal conduct or associations.” U.S.S.G. Section 3E1.1 application note 1(b). Here, the district court observed that Defendant’s forgery of the sentencing letters resembled the forgeries he submitted as part of the donation scheme, indicating that Defendant had not abandoned his criminal conduct. These were appropriate considerations.
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