U.S. v. Washington, No. 93-50786 (9th Cir.) (66 F.3d 1101) (October 4, 1995) (Judge Stephen Reinhardt)
The Court held held that the district court erred in applying Section 2J1.2(c)(1)'s cross-reference to Section 2X3.1 ("Accessory After the Fact"). Application of the cross-reference resulted in a higher offense level than Washington would have received under the specific offense characteristics of Section 2J1.2(b).2 Under the version of the Guidelines …
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