In United States v. Stubblefield, published today, the Sixth Circuit found a two-level enhancement for multiple victims under U.S.S.G. § 2B1.1(b)(2) was procedurally unreasonable because Wal-Mart is a single victim. While multiple false checks were cashed at various Cleveland Wal-Mart locations, each location is automatically reimbursed for the loss by the Wal-Mart Corporation. Only the single corporation suffered actual loss and is therefore the only victim.
The full opinion is available here.
Congratulations to Vanessa Malone here at the Northern District of Ohio!