United States v. Christian Collins, 2014 U.S. App. LEXIS 10819

Collins, a convicted felon, was a passenger in a stolen vehicle that crashed; officers found a loaded firearm nearby and took Collins into custody.
At the station Collins gave an oral and written statement admitting possession; while being asked to sign, he attempted to destroy the written statement and, when officers tried to retrieve it, grabbed a pen and twice tried to stab Detective Rudolph in the face and kicked him.
Collins was shackled to the interview room floor at the time of the violent episode and ultimately was subdued by officers.
He pled guilty to being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)).
The PSR applied a two-level obstruction enhancement under USSG § 3C1.1 (attempted destruction of evidence) and a six-level officer-assault enhancement under USSG § 3A1.2(c)(1); the district court adopted both and sentenced Collins to 100 months.
On appeal Collins challenged both enhancements; the Eighth Circuit affirmed the obstruction enhancement but vacated the § 3A1.2(c)(1) enhancement and remanded for resentencing.

Issue	Plaintiff's Argument (Collins)	Defendant's Argument (Government)	Held
Whether § 3C1.1 obstruction enhancement applies for Collins’s attempt to destroy his written statement	Collins: conduct was a panicked, non-willful reaction to Detective’s remark; not willful obstruction and not tied to the felon-in-possession offense	Government: Collins willfully tried to destroy evidence during an active interview about the firearm; the written statement related to the felon-in-possession offense	Held: Enhancement affirmed — court found Collins acted willfully and the destruction related to the felon-in-possession offense
Whether § 3A1.2(c)(1) six-level enhancement applies for assault on Detective Rudolph	Collins: assault occurred during post-arrest station interrogation, not "during the course of the offense or immediate flight therefrom"	Government: the assault was relevant conduct in attempting to avoid detection/responsibility and thus falls within "course of the offense"	Held: Enhancement vacated — court held "course of the offense" does not encompass broad relevant-conduct outside the immediate temporal scope; assault occurred after arrest and not during immediate flight

Septon v. United States, 557 F.3d 934 (Eighth Circuit) (standard of review for guideline enhancements)
Billingsley v. United States, 160 F.3d 502 (Eighth Circuit) (broad district court discretion to apply §3C1.1)
Lyon v. United States, 959 F.2d 701 (Eighth Circuit) (application of §3C1.1)
Watts v. United States, 940 F.2d 332 (Eighth Circuit) (definition of willful obstruction)
Stroud v. United States, 893 F.2d 504 (Second Circuit) (willfulness standard)
Dierling v. United States, 131 F.3d 722 (Eighth Circuit) (knowledge of investigation supports willfulness)
Oppedahl v. United States, 998 F.2d 584 (Eighth Circuit) (knowledge of investigation supports obstruction finding)
Chatmon v. United States, 742 F.3d 350 (Eighth Circuit) (possession element of §922(g)(1))
Godsey v. United States, 690 F.3d 906 (Eighth Circuit) (use of statutory-construction principles to interpret Guidelines)
Davis v. United States, 668 F.3d 576 (Eighth Circuit) (interpretive approach to Guidelines)
Salem v. United States, 587 F.3d 868 (Eighth Circuit) (plain-language approach)
Abumayyaleh v. United States, 530 F.3d 641 (Eighth Circuit) (Guidelines interpretation)
Johnson v. United States, 703 F.3d 464 (Eighth Circuit) (avoidance of surplusage in guideline reading)
Blackwell v. United States, 323 F.3d 1256 (Tenth Circuit) (discussed re: scope of "offense" but distinguished)
Holbert v. United States, 285 F.3d 1257 (Tenth Circuit) (contextualized by Blackwell on different enhancement)