Case summaries of recently decided Third Circuit criminal law cases and other relevant updates provided by Federal Defenders and CJA Panel Attorneys.
Thursday, March 13, 2014
Incomplete counterfeit bills count towards face value calculation under U.S.S.G. § 2B5.1(b)(1)
In United States v. Woronwicz, No. 12-4320 (3d Cir. March 12,2012), the Court held that incomplete counterfeit bills should be included in face value calculation under U.S.S.G. § 2B5.1(b)(1). Woronwicz was found with over $207,000 in counterfeit bills: 90% were completed on only one side, and $20,000 were completed on both sides. He pled guilty to counterfeiting in violation of 18 U.S.C. § 474. While Note 3 to § 2B5.1(b) excepts “items that are so obviously counterfeit that they are unlikely to be accepted even if subjected to only minimal scrutiny,” the reach of Note 3 is limited to subsection (b)(2). Incomplete bills, like bills of unpassable quality, all count towards (b)(1). Thus, the 12-level enhancement for counterfeit currency exceeding $200,000 was correctly applied.
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