United States First Circuit

Sentence for fraudulently obtaining and attempting to renew a passport using a stolen identity and Social Security number is affirmed where the district court did not err in applying a four-level sentencing enhancement under U.S.S.G. section 2L2.2(b)(3)(A) because a passport is not a 'means of identification' to which the enhancement cannot be applied under Application Note 2 to U.S.S.G. section 2B1.6.

Appellate Information

• Published 2016/12/20

Judges

• TORRUELLA

Court

• United States First Circuit

Counsel