United States v. Sardariani, No. 12-50418 (9th Cir. 2014)
Annotate this CaseDefendant appealed his sentence after pleading guilty to conspiring to commit wire fraud and other offenses. The court held that a notary seal can be an "authentication feature" under 18 U.S.C. 1028, and that the district court correctly applied an enhancement for use of an authentication feature under U.S.S.G. 2B1.1(b)(11)(A)(ii) when it calculated the advisory guidelines range for defendant's sentence. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal Law. Affirming a sentence for conspiring to commit wire fraud and other offenses, the panel held that a notary seal can be an “authentication feature” under 18 U.S.C. § 1028, and that the district court correctly applied an enhancement for use of an authentication feature under U.S.S.G. § 2B1.1(b)(11)(A)(ii).
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