Yesterday in Fraud

Some noteworthy white collar decisions from the federal circuits, published on 10-3-11:

U.S. v. Gilchrist (9th Cir. 2011) (Guidelines obstruction enhancement okay even if defendant did not know of pending criminal investigation)

U.S. v. King (9th Cir. 2011) (Section 1001 conviction upheld even though false statement was made to state agriculture official)

 U.S. v. Leslie (2nd Cir. 2011) (Imprisonment not withdrawal from conspiracy for purposes of establishing Guidelines loss)

U.S. v. Lee (7th Cir. 2011) (Post-prison MVRA seizure of retirement funds is limited by CCPA)

(Wisenberg)