United States v. Woodson, No. 19-1906 (6th Cir. 2020)
Annotate this CaseOver four months, Woodson and his accomplices targeted 14 Jared stores in Ohio, Indiana, Kentucky, Michigan, Illinois, and New Jersey. While inside a Jared store, Woodson would ask a clerk to see a diamond. An accomplice would then cause a disturbance, drawing the clerk’s attention. With the clerk distracted, Woodson would replace the diamond with cubic zirconia, leave the store with the diamond, and then fence the stolen item to a buyer in Toledo, Cleveland, or New York. The group stole roughly $90,000 worth of diamonds before targeting multiple Grand Rapids area Jared stores on the same day and diverting from their routine, to pry open a display case. A clerk called 911. Officers broadcast descriptions of the men to law enforcement and jewelry stores. Later that day, Woodson was identified leaving another Jared store. When police stopped his vehicle, they found Woodson and his accomplices plus several pieces of diamond jewelry. Woodson pled guilty to conspiracy, 18 U.S.C. 371, 2314, 2315. The district court calculated Woodson’s Guidelines range as 21-27 months. The Sixth Circuit affirmed his 24-month sentence, upholding the imposition of a two-level sentencing enhancement based on a finding that a central part of Woodson’s scheme was perpetual relocation to avoid law enforcement (U.S.S.G. 2B1.1(b)(10)(A). The court rejected Woodson’s argument that his practice of returning to his “home base” in Toledo meant he never “relocated” the scheme.
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