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U.S. v. Bliss, No. 04-1163-cr (2nd Cir.) (430 F.3d 640) (November 23, 2005) (Judge Thomas J. Meskill)

The Second Circuit held in this case that a defendant's flight from arrest, even when it results in a year-long delay in his apprehension by law enforcement, is not in itself sufficient to trigger the 2-level obstruction enhancement under U.S.S.G. ยง 3C1.1. Moreover, it ruled, the enhancement is not automatically ...

 

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