U.S. v. Landwer

Dist. Ct. did not err in sentencing defendant to 115-month term of incarceration on charge of mail fraud after finding existence of two-level enhancement under section 2B1.1(b)(9)(C) for use of sophisticated means to perpetuate financial scheme. Record supported instant enhancement where scheme covered period of seven years and involved defendant's use of forged documents, fictitious checks and correspondence, as well as forged real estate documents. Defendant also misled several local public officials over same time period. Ct. rejected defendant's argument that enhancement applied only to fraud that had little chance of detection by victims of scheme.