U.S. v. Bell

Dist. Ct. did not err in denying defendant's motion to dismiss indictment alleging violation of Deadbeat Parents Punishment Act on grounds that prosecution was beyond applicable statute of limitations. While defendant argued that 5-year limitations period began once his child-support arrearage exceeded $10,000, Ct. found that instant prosecution was timely since Act was continuing offense, which was not completed until offense expired. Remand, though, was required for new sentence where Dist. Ct. improperly applied enhancement for violation of court order, where said violation formed element of charged offense.