In United States v. Raia, the Third Circuit reviewed the sentence imposed after the defendant was convicted of bribery-related offenses for offering cash payments to voters during his political campaign for city council. At sentencing, the Government sought an aggravating-role enhancement under Section 3B1.1 of the Guidelines and an obstruction of justice enhancement under Section 3C1.1 of the Guidelines. The District Court denied the requested enhancements. The Third Circuit reversed, finding that the District Court made multiple errors in its interpretation of the guidelines. The Third Circuit also rejected the defendant’s argument that any errors made in calculating the guideline enhancements were harmless. As a result, the case was remanded for re-sentencing.
