United States v. Nagell, No. 17-1058 (1st Cir. 2018)
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The First Circuit affirmed Defendant’s sentence of thirty months’ imprisonment for knowingly failing to update his registration, holding that the district court neither committed clear error in finding that Defendant perjured himself at trial or in imposing a two-level enhancement for obstruction of justice.
Defendant, a registered sex offender, was convicted of knowingly failing to update his registration, in violation of 18 U.S.C. 2250(a). Finding that Defendant had committed perjury when he testified at trial in his own defense, the district court imposed a two-level obstruction of justice enhancement. The court then sentenced Defendant at the middle of his Guidelines sentencing range. The First Circuit affirmed, holding that the district court did not err in applying the sentencing enhancement for obstruction of justice because the record provided clear support for the finding that Defendant committed perjury.
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