U.S.S.G. § 2A4.1
Kidnapping, Abduction, Unlawful Restraint
(a) Base Offense Level: 32
(b) Specific Offense Characteristics
(1) If a ransom demand or a demand upon government was made, increase by 6 levels.
(2) (A) If the victim sustained permanent or life-threatening bodily injury, increase by 4 levels; (B) if the victim sustained serious bodily injury, increase by 2 levels; or (C) if the degree of injury is between that specified in subdivisions (A) and (B), increase by 3 levels.
(3) If a dangerous weapon was used, increase by 2 levels.
(4) (A) If the victim was not released before thirty days had elapsed, increase by 2 levels.
(B) If the victim was not released before seven days had elapsed, increase by 1 level.
(5) If the victim was sexually exploited, increase by 6 levels.
(6) If the victim is a minor and, in exchange for money or other consideration, was placed in the care or custody of another person who had no legal right to such care or custody of the victim, increase by 3 levels.
(7) If the victim was kidnapped, abducted, or unlawfully restrained during the commission of, or in connection with, another offense or escape therefrom; or if another offense was committed during the kidnapping, abduction, or unlawful restraint, increase to—
(A) the offense level from the Chapter Two offense guideline applicable to that other offense if such offense guideline includes an adjustment for kidnapping, abduction, or unlawful restraint, or otherwise takes such conduct into account; or
(B) 4 plus the offense level from the offense guideline applicable to that other offense, but in no event greater than level 43, in any other case,
if the resulting offense level is greater than that determined above.
(c) Cross Reference
(1) If the victim was killed under circumstances that would constitute murder under 18 U.S.C. § 1111 had such killing taken place within the territorial or maritime jurisdiction of the United States, apply §2A1.1 (First Degree Murder).
Commentary
Statutory Provisions: 18 U.S.C. §§ 115(b)(2), 351(b), (d), 1201, 1203, 1751(b), 2340A. For additional statutory provision(s), see Appendix A (Statutory Index).Application Notes:
1. For purposes of this guideline–Definitions of "serious bodily injury" and "permanent or life-threatening bodily injury" are found in the Commentary to §1B1.1 (Application Instructions). However, for purposes of this guideline, "serious bodily injury" means conduct other than criminal sexual abuse, which is taken into account in the specific offense characteristic under subsection (b)(5).
2. "A dangerous weapon was used" means that a firearm was discharged, or a "firearm" or "dangerous weapon" was "otherwise used" (as defined in the Commentary to §1B1.1 (Application Instructions)). 3. "Sexually exploited" includes offenses set forth in 18 U.S.C. §§ 2241–2244, 2251, and 2421–2423. 4. In the case of a conspiracy, attempt, or solicitation to kidnap, §2X1.1 (Attempt, Solicitation, or Conspiracy) requires that the court apply any adjustment that can be determined with reasonable certainty. Therefore, for example, if an offense involved conspiracy to kidnap for the purpose of committing murder, subsection (b)(7) would reference first degree murder (resulting in an offense level of 43, subject to a possible 3-level reduction under §2X1.1(b)).Similarly, for example, if an offense involved a kidnapping during which a participant attempted to murder the victim under circumstances that would have constituted first degree murder had death occurred, the offense referenced under subsection (b)(7) would be the offense of first degree murder.
Background: Federal kidnapping cases generally encompass three categories of conduct: limited duration kidnapping where the victim is released unharmed; kidnapping that occurs as part of or to facilitate the commission of another offense (often, sexual assault); and kidnapping for ransom or political demand.The guideline contains an adjustment for the length of time that the victim was detained. The adjustment recognizes the increased suffering involved in lengthy kidnappings and provides an incentive to release the victim.
An enhancement is provided when the offense is committed for ransom (subsection (b)(1)) or involves another federal, state, or local offense that results in a greater offense level (subsections (b)(7) and (c)(1)).
Section 401 of Public Law 101–647 amended 18 U.S.C. § 1201 to require that courts take into account certain specific offense characteristics in cases involving a victim under eighteen years of age and directed the Commission to include those specific offense characteristics within the guidelines. Where the guidelines did not already take into account the conduct identified by the Act, additional specific offense characteristics have been provided.
Subsections (a) and (b)(5), and the deletion of subsection (b)(4)(C), effective May 30, 2003, implement the directive to the Commission in section 104 of Public Law 108–21.
Historical Note: Effective November 1, 1987. Amended effective November 1, 1989 (amendment 96); November 1, 1991 (amendment 363); November 1, 1992 (amendment 445); November 1, 1993 (amendment 478); November 1, 1997 (amendment 545); November 1, 2002 (amendment 637); May 30, 2003 (amendment 650); October 27, 2003 (amendment 651).
Notes of Decisions
Cited in 242
cases (38 in the last 5 years), 1990–2026 · leading case: United States v. Belfast, 611 F.3d 783 (11th Cir. 2010).
United States v. Belfast, 611 F.3d 783 (11th Cir. 2010). “The PSI applied U.S.S.G. § 2A4.1, the provision relating to kidnapping, abduction, and other unlawful restraints, to the ten offense groups, yielding a base offense level of 24.”
United States v. Jean Carlo Ferreira, 275 F.3d 1020 (11th Cir. 2001). “” U.S.S.G. § 2A4.1, comment, (n.5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Torrealba, 339 F.3d 1238 (11th Cir. 2003). “” U.S.S.G. § 2A4.1, comment, (n. 5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Richard Cole, III Jonathan Johnson, 359 F.3d 420 (6th Cir. 2004). “1, instead of U.S.S.G. § 2A4.1 for the kidnapping offense; (2) the district court should not have granted a four-level sentence enhancement for abduction on a conviction for a kidnapping offense pursuant to U.”
United States v. Dean A. Lambey, 974 F.2d 1389 (4th Cir. 1992). “5 Because there is no guideline section expressly covering a conspiracy to kidnap, the district court turned to the guideline for the “object offense” of kidnapping, found at U.S.S.G. § 2A4.1 (Kidnapping, Abduction, Unlawful Restraint).”
United States v. James Howard Van Metre, United States of Am. v. James Howard Van Metre, 150 F.3d 339 (4th Cir. 1998). “U.S.S.G. § 2A4.1, comment, (backg’d.) (“Federal kidnapping cases generally encompass three categories of conduct: limited duration kidnapping where the victim is released unharmed; kidnapping that occurs as part of or to -facilitate the commission of another offense (often,…”
United States v. Lindani Mzembe, 933 F.3d 796 (7th Cir. 2019). “One issue under the Sentencing Guidelines was how to categorize Harris's injuries under U.S.S.G. § 2A4.1(b)(2)(A), which adds four levels for "permanent or life-threatening bodily injury," two levels for "serious bodily injury," or three levels for something in between.”
United States v. Luis Cedillo-Narvaez, 761 F.3d 397 (5th Cir. 2014). “1 with U.S.S.G. § 2A4.1. In Angeles-Mendoza, we acknowledged that an undocumented alien’s illegal status could be the basis for a “vulnerable victim” finding for offenses that do not necessarily involve illegal aliens: renew his objection orally was “immaterial” and stated: “We…”
United States v. Lorenzo Hernandez, 279 F.3d 19 (1st Cir. 2002). “Sentencing Guidelines The district court judge sentenced Lorenzo-Hernández by applying the sentencing guideline for kidnapping, U.S.S.G. § 2A4.1. He applied a six-level enhancement in accordance with U.”
United States v. Alvarez-Cuevas, 415 F.3d 121 (1st Cir. 2005). “Nonetheless, USSG § 2A4.1 applies to hostage taking because that section.”
United States v. Pedro Rafael Caraballo-Martinez, 866 F.3d 1233 (11th Cir. 2017). “One- of Carabal-lo’s codefendants raised a new objection— that the two-level enhancement for the use of a dangerous weapon under U.S.S.G. § 2A4.1(b)(3) was inappropriate in light of the five-year consecutive sentence for the 18 U.”
United States v. Anderson, 5 F.3d 795 (5th Cir. 1993). “The PSIs began calculations of the defendants’ offense levels with the kidnapping guideline, U.S.S.G. § 2A4.1, which carries a base offense level of 24.”
— U.S.S.G. §2A4.1(2)(B) — 1 case
United States v. Pedro Silva Ochoa (11th Cir. 2026).
— U.S.S.G. §2A4.1(3) — 1 case
United States v. Einstman, 325 F. Supp. 2d 373 (S.D.N.Y. 2004).
— U.S.S.G. §2A4.1(5) — 4 cases
United States v. Rodney L. Tipton (92-6286) & Robert A. Davis (92-6287), 11 F.3d 602 (6th Cir. 1994).
United States v. Rodney Pollard, 986 F.2d 44 (3rd Cir. 1993).
United States v. Pedro Silva Ochoa (11th Cir. 2026).
United States v. McGuire, 441 F. App'x 586 (10th Cir. 2011).
— U.S.S.G. §2A4.1(7) — 1 case
United States v. Einstman, 325 F. Supp. 2d 373 (S.D.N.Y. 2004).
— U.S.S.G. §2A4.1(a) — 33 cases
United States v. Yannotti, 541 F.3d 112 (2d Cir. 2008).
United States v. Fields, 242 F.3d 393 (D.C. Cir. 2001).
United States v. Rivas-Lopez, 678 F.3d 353 (5th Cir. 2012).
United States v. Angelos, 345 F. Supp. 2d 1227 (D. Utah 2004).
United States v. Anderson, 5 F.3d 795 (5th Cir. 1993). “The PSIs began calculations of the defendants’ offense levels with the kidnapping guideline, U.S.S.G. § 2A4.1, which carries a base offense level of 24.”
— U.S.S.G. §2A4.1(a)(l) — 1 case
United States v. Alvarez-Cuevas, 415 F.3d 121 (1st Cir. 2005). “Nonetheless, USSG § 2A4.1 applies to hostage taking because that section.”
— U.S.S.G. §2A4.1(b) — 7 cases
United States v. Belfast, 611 F.3d 783 (11th Cir. 2010). “The PSI applied U.S.S.G. § 2A4.1, the provision relating to kidnapping, abduction, and other unlawful restraints, to the ten offense groups, yielding a base offense level of 24.”
United States v. Yuris Bonilla-Guizar, 729 F.3d 1179 (9th Cir. 2013).
United States v. Calderon-Lopez, 268 F. App'x 279 (5th Cir. 2008).
United States v. Nicolella, 211 F. App'x 12 (1st Cir. 2007).
United States v. Merise (D.D.C. 2023).
— U.S.S.G. §2A4.1(b)(1) — 19 cases
United States v. Torrealba, 339 F.3d 1238 (11th Cir. 2003). “” U.S.S.G. § 2A4.1, comment, (n. 5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Jean Carlo Ferreira, 275 F.3d 1020 (11th Cir. 2001). “” U.S.S.G. § 2A4.1, comment, (n.5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Julio Fernandez, 770 F.3d 340 (5th Cir. 2014).
United States v. John Digiorgio, Matthew Nocerino A.K.A. Mattie, 193 F.3d 1175 (11th Cir. 1999).
United States v. Sierra-Velasquez, 310 F.3d 1217 (9th Cir. 2002).
— U.S.S.G. §2A4.1(b)(2) — 10 cases
United States v. Jean Carlo Ferreira, 275 F.3d 1020 (11th Cir. 2001). “” U.S.S.G. § 2A4.1, comment, (n.5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Torrealba, 339 F.3d 1238 (11th Cir. 2003). “” U.S.S.G. § 2A4.1, comment, (n. 5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Yannotti, 541 F.3d 112 (2d Cir. 2008).
United States v. John Patino, 962 F.2d 263 (2d Cir. 1992).
United States v. James Howard Van Metre, United States of Am. v. James Howard Van Metre, 150 F.3d 339 (4th Cir. 1998). “U.S.S.G. § 2A4.1, comment, (backg’d.) (“Federal kidnapping cases generally encompass three categories of conduct: limited duration kidnapping where the victim is released unharmed; kidnapping that occurs as part of or to -facilitate the commission of another offense (often,…”
— U.S.S.G. §2A4.1(b)(2)(A) — 12 cases
United States v. Lindani Mzembe, 933 F.3d 796 (7th Cir. 2019). “One issue under the Sentencing Guidelines was how to categorize Harris's injuries under U.S.S.G. § 2A4.1(b)(2)(A), which adds four levels for "permanent or life-threatening bodily injury," two levels for "serious bodily injury," or three levels for something in between.”
United States v. Nigel Medlin, 65 F.4th 326 (6th Cir. 2023).
United States v. Torrealba, 339 F.3d 1238 (11th Cir. 2003). “” U.S.S.G. § 2A4.1, comment, (n. 5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Kendrick Frazier, 129 F.4th 392 (7th Cir. 2025).
United States v. Tonda Watkins Wright, 119 F.3d 390 (6th Cir. 1997).
— U.S.S.G. §2A4.1(b)(2)(B) — 18 cases
United States v. Monclaire Saint Louis, 889 F.3d 145 (4th Cir. 2018).
United States v. William Joseph Harris, 243 F.3d 806 (4th Cir. 2001).
United States v. Davis, 19 F.3d 166 (5th Cir. 1994).
United States v. Jenkins, 122 F. Supp. 3d 639 (E.D. Ky. 2013).
United States v. Chang Han Chen, A/K/A 34, United States of Am. v. Chong Chao Chen, A/K/A 21, 131 F.3d 375 (4th Cir. 1997).
— U.S.S.G. §2A4.1(b)(3) — 53 cases
United States v. Ronnie Lee Douglas, Jr., 489 F.3d 1117 (11th Cir. 2007).
United States v. Lindani Mzembe, 933 F.3d 796 (7th Cir. 2019). “One issue under the Sentencing Guidelines was how to categorize Harris's injuries under U.S.S.G. § 2A4.1(b)(2)(A), which adds four levels for "permanent or life-threatening bodily injury," two levels for "serious bodily injury," or three levels for something in between.”
United States v. Pedro Rafael Caraballo-Martinez, 866 F.3d 1233 (11th Cir. 2017). “One- of Carabal-lo’s codefendants raised a new objection— that the two-level enhancement for the use of a dangerous weapon under U.S.S.G. § 2A4.1(b)(3) was inappropriate in light of the five-year consecutive sentence for the 18 U.”
United States v. Luis Cedillo-Narvaez, 761 F.3d 397 (5th Cir. 2014). “1 with U.S.S.G. § 2A4.1. In Angeles-Mendoza, we acknowledged that an undocumented alien’s illegal status could be the basis for a “vulnerable victim” finding for offenses that do not necessarily involve illegal aliens: renew his objection orally was “immaterial” and stated: “We…”
United States v. Yuris Bonilla-Guizar, 729 F.3d 1179 (9th Cir. 2013).
— U.S.S.G. §2A4.1(b)(4) — 2 cases
United States v. James Howard Van Metre, United States of Am. v. James Howard Van Metre, 150 F.3d 339 (4th Cir. 1998). “U.S.S.G. § 2A4.1, comment, (backg’d.) (“Federal kidnapping cases generally encompass three categories of conduct: limited duration kidnapping where the victim is released unharmed; kidnapping that occurs as part of or to -facilitate the commission of another offense (often,…”
United States v. Rowsey, 431 F. Supp. 2d 903 (N.D. Ind. 2006).
— U.S.S.G. §2A4.1(b)(4)(A) — 3 cases
United States v. Ahmed Amer, 110 F.3d 873 (2d Cir. 1997).
United States v. Newton Alfred Winn, 948 F.2d 145 (5th Cir. 1991).
United States v. Rami Saba, 526 F. App'x 489 (6th Cir. 2013).
— U.S.S.G. §2A4.1(b)(4)(B) — 4 cases
United States v. Lorenzo Hernandez, 279 F.3d 19 (1st Cir. 2002). “Sentencing Guidelines The district court judge sentenced Lorenzo-Hernández by applying the sentencing guideline for kidnapping, U.S.S.G. § 2A4.1. He applied a six-level enhancement in accordance with U.”
United States v. Mariece Sims, 161 F. App'x 849 (11th Cir. 2006).
United States v. Timothy Caskey, 636 F. App'x 376 (8th Cir. 2016).
United States v. Ortiz-De Leon (5th Cir. 2024).
— U.S.S.G. §2A4.1(b)(4)(C) — 10 cases
United States v. Richard Cole, III Jonathan Johnson, 359 F.3d 420 (6th Cir. 2004). “1, instead of U.S.S.G. § 2A4.1 for the kidnapping offense; (2) the district court should not have granted a four-level sentence enhancement for abduction on a conviction for a kidnapping offense pursuant to U.”
United States v. Pedro Mezas De Jesus, 217 F.3d 638 (9th Cir. 2000).
United States v. Eldon v. Coates, 996 F.2d 939 (8th Cir. 1993).
United States v. Joey J. Hicks, 106 F.3d 187 (7th Cir. 1997).
United States v. Michael J. Sickinger, 179 F.3d 1091 (8th Cir. 1999).
— U.S.S.G. §2A4.1(b)(5) — 27 cases
United States v. Dean A. Lambey, 974 F.2d 1389 (4th Cir. 1992). “5 Because there is no guideline section expressly covering a conspiracy to kidnap, the district court turned to the guideline for the “object offense” of kidnapping, found at U.S.S.G. § 2A4.1 (Kidnapping, Abduction, Unlawful Restraint).”
United States v. James Howard Van Metre, United States of Am. v. James Howard Van Metre, 150 F.3d 339 (4th Cir. 1998). “U.S.S.G. § 2A4.1, comment, (backg’d.) (“Federal kidnapping cases generally encompass three categories of conduct: limited duration kidnapping where the victim is released unharmed; kidnapping that occurs as part of or to -facilitate the commission of another offense (often,…”
United States v. Jean Carlo Ferreira, 275 F.3d 1020 (11th Cir. 2001). “” U.S.S.G. § 2A4.1, comment, (n.5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States of Am., Cross-Appellant v. Lee D. Holmes, Cross-Appellee, 975 F.2d 275 (6th Cir. 1992).
United States v. Michelle Lyn Michaud, 268 F.3d 728 (9th Cir. 2001).
— U.S.S.G. §2A4.1(b)(5)(A) — 3 cases
United States v. Richard Cole, III Jonathan Johnson, 359 F.3d 420 (6th Cir. 2004). “1, instead of U.S.S.G. § 2A4.1 for the kidnapping offense; (2) the district court should not have granted a four-level sentence enhancement for abduction on a conviction for a kidnapping offense pursuant to U.”
United States v. Boggs, 170 F. App'x 841 (4th Cir. 2006).
United States v. Johnson (6th Cir. 2004).
— U.S.S.G. §2A4.1(b)(6) — 5 cases
United States v. Alvarez-Cuevas, 415 F.3d 121 (1st Cir. 2005). “Nonetheless, USSG § 2A4.1 applies to hostage taking because that section.”
United States v. Luis Cedillo-Narvaez, 761 F.3d 397 (5th Cir. 2014). “1 with U.S.S.G. § 2A4.1. In Angeles-Mendoza, we acknowledged that an undocumented alien’s illegal status could be the basis for a “vulnerable victim” finding for offenses that do not necessarily involve illegal aliens: renew his objection orally was “immaterial” and stated: “We…”
United States v. Matthews, 225 F. Supp. 2d 893 (N.D. Ill. 2002).
United States v. Alvarez-Cuevas, 210 F. App'x 23 (1st Cir. 2007).
United States v. Ortiz-De Leon (5th Cir. 2024).
— U.S.S.G. §2A4.1(b)(7) — 19 cases
United States v. Lewis, 115 F.3d 1531 (11th Cir. 1997).
United States v. Richard Cole, III Jonathan Johnson, 359 F.3d 420 (6th Cir. 2004). “1, instead of U.S.S.G. § 2A4.1 for the kidnapping offense; (2) the district court should not have granted a four-level sentence enhancement for abduction on a conviction for a kidnapping offense pursuant to U.”
United States v. Belfast, 611 F.3d 783 (11th Cir. 2010). “The PSI applied U.S.S.G. § 2A4.1, the provision relating to kidnapping, abduction, and other unlawful restraints, to the ten offense groups, yielding a base offense level of 24.”
United States v. Gary Saknikent, 30 F.3d 1012 (8th Cir. 1994).
United States v. George Dean Martin, 157 F.3d 46 (2d Cir. 1998).
— U.S.S.G. §2A4.1(b)(7)(A) — 7 cases
United States v. Jon Bryant, Sr., 913 F.3d 783 (8th Cir. 2019).
United States v. Richard Cole, III Jonathan Johnson, 359 F.3d 420 (6th Cir. 2004). “1, instead of U.S.S.G. § 2A4.1 for the kidnapping offense; (2) the district court should not have granted a four-level sentence enhancement for abduction on a conviction for a kidnapping offense pursuant to U.”
United States v. Mitchell Dean Cree, 166 F.3d 1270 (8th Cir. 1999).
United States v. Boggs, 170 F. App'x 841 (4th Cir. 2006).
United States v. Morgan, 33 F. App'x 907 (9th Cir. 2002).
— U.S.S.G. §2A4.1(b)(7)(B) — 5 cases
United States v. Fields, 242 F.3d 393 (D.C. Cir. 2001).
United States v. Mabel Lee Gray, 16 F.3d 681 (6th Cir. 1994).
United States v. Cruz, 101 F. App'x 612 (6th Cir. 2004).
United States v. Sencion, 38 F. App'x 638 (2d Cir. 2002).
United States v. Matthew Scharber (9th Cir. 2021).
— U.S.S.G. §2A4.1(b)(l) — 22 cases
United States v. Jean Carlo Ferreira, 275 F.3d 1020 (11th Cir. 2001). “” U.S.S.G. § 2A4.1, comment, (n.5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Vizcarra, 668 F.3d 516 (7th Cir. 2012).
United States v. Torrealba, 339 F.3d 1238 (11th Cir. 2003). “” U.S.S.G. § 2A4.1, comment, (n. 5). Reading the commentary alongside the guideline language, the district court concluded that an enhancement is appropriate if it could be determined “with reasonable certainty” that a ransom demand would have been made but for the appellants’…”
United States v. Pedro Rafael Caraballo-Martinez, 866 F.3d 1233 (11th Cir. 2017). “One- of Carabal-lo’s codefendants raised a new objection— that the two-level enhancement for the use of a dangerous weapon under U.S.S.G. § 2A4.1(b)(3) was inappropriate in light of the five-year consecutive sentence for the 18 U.”
United States v. De Jesus-Batres, 410 F.3d 154 (5th Cir. 2005).
— U.S.S.G. §2A4.1(c) — 7 cases
United States v. Belfast, 611 F.3d 783 (11th Cir. 2010). “The PSI applied U.S.S.G. § 2A4.1, the provision relating to kidnapping, abduction, and other unlawful restraints, to the ten offense groups, yielding a base offense level of 24.”
Camacho v. English, 872 F.3d 811 (7th Cir. 2017).
United States v. Malkit \Mike\" Singh & Ekabal \"Paul\" Busara", 483 F.3d 489 (7th Cir. 2007).
United States v. Leifson, 568 F.3d 1215 (10th Cir. 2009).
United States v. Roy M. Belfast, Jr. (11th Cir. 2010).
— U.S.S.G. §2A4.1(c)(1) — 2 cases
United States v. Leobardo Barraza, 982 F.3d 1106 (8th Cir. 2020).
United States v. Nathaniel Harris (11th Cir. 2025).
— U.S.S.G. §2A4.1(c)(l) — 2 cases
United States v. Sarracino, 131 F.3d 943 (10th Cir. 1997).
United States v. Rami Saba, 526 F. App'x 489 (6th Cir. 2013).
— U.S.S.G. §2A4.1(e) — 2 cases
United States v. Belfast, 611 F.3d 783 (11th Cir. 2010). “The PSI applied U.S.S.G. § 2A4.1, the provision relating to kidnapping, abduction, and other unlawful restraints, to the ten offense groups, yielding a base offense level of 24.”
Camacho v. English, 872 F.3d 811 (7th Cir. 2017).
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