Class Disruptions Warranted Enhancement in False Bomb Threat Case

U.S. v. Anwar, -- F.3d --, 2013 WL 6727480 (12/23/13)(published) - The district court properly determined that Mr. Anwar's bomb threats resulted in a substantial disruption of public, governmental, or business functions or services and warranted a four-level enhancement under USSG § 2A6.1(b)(4)(A). In order to avoid an important test, Mr. Anwar, an engineering student, phoned in a false threat to detonate a bomb at New Mexico State University--leading to the shut-down of a class building, the evacuation of 240 people, and the interruption of 14 classes. The interruption to NMSU functions and services was significant in scope and length; the false threats diverted numerous NMSU employees and police and fire department officers from their regular duties.