Yesterday in Fraud

Some noteworthy white collar decisions from the federal circuits, published on 10-3-11:

U.S. v. Gilchrist (9th Cir. 2011) (Guidelines obstruction enhancement okay even if defendant did not know of pending criminal investigation)

U.S. v. King (9th Cir. 2011) (Section 1001 conviction upheld even though false statement was made to state agriculture official)

 U.S. v. Leslie (2nd Cir. 2011) (Imprisonment not withdrawal from conspiracy for purposes of establishing Guidelines loss)

U.S. v. Lee (7th Cir. 2011) (Post-prison MVRA seizure of retirement funds is limited by CCPA)

(Wisenberg)


One response to “Yesterday in Fraud”

  1. That Seventh Circuit restitution collection case, Lee, is quite remarkable, particularly in light of 18 U.S.C. s 3613(a)(1) (made applicable by 3613(f)), a statute I would describe as “on point,” but which is not discussed in the opinion.

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