United States First Circuit

Medicare and Medicaid audits had an adequate link to ensuing criminal fraud and obstruction proceedings, and thus were during the course of the investigation of the offense of conviction, for purposes of a U.S.S.G. section 3C1.1 obstruction of justice enhancement.

Appellate Information

• Decided 05/21/2003
• Published 05/21/2003

Judges

Court

• United States First Circuit

Counsel