United States v. Taylor

Willfully withholding materially false information to persuade or otherwise attempt to persuade a judge may permit a judge to add an obstruction of justice enhancement to a defendant’s pending case under the U.S. Sentencing Guidelines Manual § 3C1.1.

Terazze Taylor was arrested for fraudulently submitting travel vouchers to the Veteran’s Administration for reimbursement. After Taylor’s arrest, he was released on bond with the condition of not committing another felony. Soon after his release, Taylor was charged with domestic violence for assaulting his ex-girlfriend. While Taylor and the ex-girlfriend denied the allegations, two police officers and an independent eyewitness verified the violence charges. Additionally, a GPS tracking device put Taylor at the scene of the crime. The district court held that an assault had been committed based upon the evidence presented. Additionally, the district court determined that Taylor had provided false testimony, which resulted in a two-level increase in the offense of fraud under the obstruction of justice enhancement of U.S. Sentencing Guidelines Manual § 3C1.1. On appeal, Taylor argued that the bond revocation hearing was not related closely enough to the charge of domestic violence to permit the obstruction of justice enhancement. The Ninth Circuit held that the prosecution of domestic violence does relate to other charges pending adjudication because there is no requirement that conduct relating to the obstruction of justice substantively relate to the offense in which the defendant is being accused of, and the bond revocation hearing directly relates to a federal offense. Accordingly, the panel found that the district court correctly found that Taylor had a willful intent to mislead the magistrate, thereby obstructing justice. AFFIRMED.