Second Circuit - Other Offense Types

United States v. Houtar, 980 F.3d 268 (2d Cir. 2020). Section 2L2.2(b)(3)’s 4-level enhancement for fraudulent use of a U.S. passport does not require a defendant to present his physical passport when applying for a replacement; use of the passport number and expiration date is sufficient.

United States v. Houtar, 980 F.3d 268 (2d Cir. 2020). The court did not err in applying §2J1.2(b)(2)’s 3-level enhancement for substantial interference with the administration of justice. The defendant’s flight impaired the family court’s ability to enforce its visitation order, and that conduct was not necessary to sustain the conviction for parental kidnapping.

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