U.S. v. Zamora

Dist. Ct. did not err in imposing sentence on charge of bribing federal official that included enhancement under section 2C1.1(b)(3) of USSG for bribery offense that involved public official in high-level decision making or sensitive position. Instant offense concerned defendant’s bribes to prison guard to smuggle contraband into prison on behalf of defendant and other prisoners. Ct. rejected defendant’s contention that instant non-supervisory prison guard did not qualify as official in sensitive position for purposes of imposing instant enhancement. Ct. also rejected defendant’s claim that enhancement applied only to bribes made for purpose of influencing official public act, as opposed to bribes that facilitated criminal activity.