Wednesday, September 27, 2006

Endeavoring. The Second Circuit addressed the issue of whether the cross-reference of United States Sentencing Guidelines 2J1.2 with 2X3.1 for cases "involving obstruction" of an investigation applies when there was no actual obstruction, but merely an "endeavor" to obstruct justice. The Second Circuit held that that cross-reference does apply whether there is actual obstruction or merely an endeavor to do so.

The decision in United States v. Giovanelli can be found here.

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