Fifth Circuit - Sex Offenses

United States v. Haas, 986 F.3d 467 (4th Cir. 2021). The court erred in applying the four-level enhancement at §2G2.1 for an offense involving a minor under 12 years of age based on a private citizen representing that a fictitious child could be made available for sexual activity. The guideline refers only to “law enforcement officer[s]” and not to private citizens “with no semblance of official authority”.

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