United States v. Jennings, No. 11-50315 (9th Cir. 2013)
Annotate this CaseDefendants appealed the application of a "sophisticated means" enhancement imposed by the district court, pursuant to U.S.S.G. 2T1(b)(2), in determining their sentences following convictions for tax fraud. The court affirmed the judgment, holding that conduct need not involve highly complex schemes or exhibit exceptional brilliance to justify a sophisticated means enhancement. In this instance, the court concluded that defendants' effort to conceal income by using a bank account with a deceptive name was sufficiently sophisticated to support application of the sentencing enhancement.
Court Description: Criminal Law. The panel affirmed the district court’s application of a “sophisticated means” enhancement under U.S.S.G. § 2T1.1(b)(2) in determining two defendants’ sentences following convictions for tax fraud. The panel held that conduct need not involve highly complex schemes or exhibit exceptional brilliance to justify a sophisticated means enhancement, and that the defendants’ efforts to conceal income by using a bank account with a deceptive name was sufficiently sophisticated to support application of the enhancement.
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