Obstruction Enhancement Warranted For Swallowing Contraband

U.S. v. Bedford, -- F.3d --, 2006 WL 1217269 (10th Cir. 5/8/06) - COA affirms § 3C1.1 enhancement for obstruction of justice because Mr. Bedford willfully swallowed crack cocaine he possessed before his arrest and he later attempted to conceal his vomit at the police station.