Tuesday, August 05, 2008

Offense Improperly Grouped

U.S. v. Hasson, 2008 WL 2894087 (7/29/08) (unpub'd) - It was reversible error to add the enhancement for one of the offenses (money laundering) after grouping all the offenses. Adding the enhancement to an offense that had a lower base offense level before grouping, as should have been done, would result in a 57-month reduction in the bottom of the guideline range.