Sixth Circuit - Relevant Conduct

United States v. Bailey, 973 F.3d 548 (6th Cir. 2020). The court applied the wrong legal standard to determine loss under §2B1.1(b)(1). Relevant conduct “is significantly narrower than the conduct embraced by the law of conspiracy,” and to be held accountable for the acts and omissions of others, those acts must be, among other things, within “the scope of the criminal activity that the particular defendant agreed to jointly undertake.”

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