"Minors" Must Actually Be Minors for 2G1.3 Enhancement to Apply

U.S. v. Hill, 2007 WL 2430135 (8/29/07)(unpub'd) - The d.ct. committed reversible plain error when it incorrectly applied an enhancement under USSG § 2G1.3 on the grounds that two of the victims were minors, when in fact they were not minors. The fact that the sentence imposed was 22 months above the correct guideline range established the error seriously affected the fairness, integrity or public reputation of judicial proceedings.