U.S. v. Nduribe

Dist. Ct. did not err in sentencing defendant to 166-month term of incarceration on drug charges after finding that defendant was eligible for obstruction of justice enhancement arising out of his flight from country in effort to evade his impending arrest on said charges. While defendant argued that his conduct in evading arrest did not qualify as obstruction of justice, Ct. found that defendant’s flight over five-year period of time, during which defendant traveled to two different countries and used alias, qualified as obstruction of justice since defendant’s conduct significantly burdened police investigation and prosecution of instant drug charges. Moreover, defendant’s warning to co-conspirator that police were about to effectuate arrest also qualified as independent basis for obstruction of justice enhancement.