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Article • April 1, 2001 • from P&J April, 2001
U.S. v. Sonsalla, No. 00-3454 (7th Cir.) (241 F.3d 904) (March 1, 2001) (Judge Joel L. Flaum) by In the case the Court rejected the defendant's contention that the district court had improperly enhanced his sentence for "more than minimal planning" pursuant to U.S.S.G. § 2F1.1(b)(2)(A), based on a finding …
Article • July 1, 1998 • from P&J July, 1998
U.S. v. Phath, No. 97-2213 (1st Cir.) (144 F.3d 146) (May 20, 1998) (Judge Norman H. Stahl) by This is one of those inscrutable decisions that's kind of hard to figure out. Here, the defendant was convicted of bank fraud after depositing two counterfeit checks in a savings bank and …
Article • December 1, 1997 • from P&J December, 1997
U.S. v. Stein, No. 96-30150 (9th Cir.) (127 F.3d 777) (October 7, 1997) (Judge Alfred T. Goodwin) by Case held that a combination of "more than minimal planning" and "scheme to defraud more than one victim" did not warrant and upward departure.
Article • December 1, 1997 • from P&J December, 1997
U.S. v. Wells, No. 93-3924 (8th Cir.) (127 F.3d 739) (October 14, 1997) (Judge Michael J. Melloy) by The Court noted that "more than minimal planning 'is deemed present in any case involving repeated acts over a period of time, unless it is clear that each instance was purely opportune'." …
Article • January 1, 1994
U.S. v. Rosa, No. 93-1120, No. 430 (2nd Cir.) (17 F.3d 1531) (February 23, 1994) (Judge Amalya Lyle Kearse) by Here the Court held that the language in USSG § 2B1.1(b)(4) which directs a two-level enhancement if the offense involved "more than minimal planning" does not require the defendant's personal …