Seventh Circuit - Other Offense Types

United States v. Zamora, 982 F.3d 1080 (7th Cir. 2020). The 4-level enhancement at §2C1.1(b)(3) for bribing a public official in a sensitive position applies to a non-supervisory prison guard. The enhancement also applies to a bribe made to influence an unofficial act, that is, an act that would be illegal even without the bribe.

United States v. Ford, 988 F.3d 970 (7th Cir. 2021). The 6-level enhancement at §2B3.1(b)(2)(B) applied to a defendant whose codefendant “otherwise used” a firearm during an attempted robbery of a gas station. There was “ample evidence” that the defendant was in on his codefendant’s plan to rob the gas station “from the start and that he continued to help after [the codefendant] brandished the firearm.” These facts supported a reasonable inference that the use of the firearm was within the scope of the defendant’s “jointly undertaken criminal activity, in furtherance of it, and reasonably foreseeable,” as required by §1B1.3(a)(1)(B).

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