In United States v. Strange, No. 21-2923, the United States Court of Appeals for the Second Circuit upheld a sentence imposed by the District Court for the District of Connecticut, which included an obstruction of justice enhancement and denied a sentence reduction for acceptance of responsibility. Tyler Criminal Defense Blog
Strange, a former senior supervisor at Collins Aerospace, was sentenced to 57 months in prison for wire fraud after using a company charitable donation matching program to siphon off approximately $600,000 for personal use.
At sentencing, Strange submitted three letters to the court advocating for leniency. However, the government discovered that Strange had forged these letters. Consequently, the prosecution sought and obtained a two-level obstruction of justice enhancement under U.S.S.G. § 3C1.1 and opposed a three-level reduction for acceptance of responsibility under U.S.S.G. § 3E1.1.
On appeal, Strange argued that the obstruction enhancement was incorrect as the forged letters did not relate to his offense of conviction or any relevant conduct, and were immaterial. The Second Circuit rejected these arguments, affirming that submitting false information capable of influencing the sentence constitutes obstruction of justice under U.S.S.G. § 3C1.1. It held that the letters were material as they would have influenced the court's decision had they been legitimate.
Under U.S.S.G. § 3C1.1, the application of the two-level obstruction enhancement is appropriate if:
(1) the defendant willfully obstructed or impeded, or attempted to obstruct or impede, the administration of justice with respect to the investigation, prosecution, or sentencing of the instant offense of conviction, and (2) the obstructive conduct related to (A) the defendant's offense of conviction and any relevant conduct; or (B) a closely related offense.
Strange also contested the denial of the acceptance of responsibility reduction, arguing that he had pleaded guilty and expressed responsibility for his actions. The court disagreed, noting that a guilty plea alone is not sufficient for this reduction, particularly when coupled with conduct that indicates non-acceptance of responsibility, such as obstruction of justice. The court found no error in the District Court's decision to deny the reduction, particularly given the similarities between the fraudulent conduct in the case and the subsequent forgery of letters.
This blog post was prepared with the assistance of ChatGPT-4 AI. Nothing in this post should be considered legal advice or the creation of an attorney-client relationship. This blog is strictly for informational purposes only.