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U.S. v. O'Brien, No. 93-30287 (9th Cir.) (50 F.3d 751) (March 23, 1995) (Judge Thomas Tang)

Case is noted for its holding that an enhancement for vlunerable victim under § 3A1.1(b) does not require the defendant to "target" his victims; the test is whether the defendant "knew or reasonably shopuld have known" that victim was vulnerable.

In this case the Ninth Circuit disagrees with the holdings …

 

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