United States v. Demetrius Woodson, 960 F.3d 852

Over four months Woodson and accomplices stole about $90,000 in diamonds from 14 Jared stores across six states using a distraction-and-swap scheme (replacing real diamonds with cubic zirconia in display clamps).
Stolen diamonds were fenced to buyers in Toledo, Cleveland, or New York; conspirators recruited accomplices and coordinated parts of the scheme from Toledo, which Woodson calls the conspirators’ “home base.”
The scheme ended after a Grand Rapids incident led to identification, a traffic stop, and recovery of jewelry; Woodson pleaded guilty to conspiracy under 18 U.S.C. §§ 371, 2314, 2315.
The district court applied a two-level Guidelines enhancement under U.S.S.G. § 2B1.1(b)(10)(A) for relocating a fraudulent scheme to another jurisdiction to evade law enforcement and calculated a 21–27 month range, imposing a 24-month sentence.
Woodson appealed, arguing that returning to Toledo meant the scheme never “relocated” for Guidelines purposes.
The Sixth Circuit affirmed, holding the enhancement applies where travel to other jurisdictions to avoid detection is a key component, even if some scheme functions occur at a stationary home base.

Issue	Woodson's Argument	Government's Argument	Held
Whether U.S.S.G. § 2B1.1(b)(10)(A) applies when conspirators operate from a fixed “home base” but travel to other jurisdictions as part of the fraud	The scheme retained a fixed hub in Toledo, so it never "relocated" for purposes of the enhancement	Relocation enhancement covers schemes where roving activity to other jurisdictions to evade detection is a central component, regardless of a home base	Enhancement applies because traveling to other jurisdictions to avoid detection was integral to the scheme; affirmation of district court

United States v. Hessa, [citation="464 F. App'x 473"] (6th Cir. 2012) (applies relocation enhancement where travel to avoid detection was integral)
United States v. Thornton, [citation="718 F. App'x 399"] (6th Cir. 2018) (relocation need not reflect a permanent change of headquarters)
United States v. Havis, 927 F.3d 382 (6th Cir. 2019) (textual approach to Guidelines interpretation)
United States v. Savarese, 686 F.3d 1 (1st Cir. 2012) (relocation enhancement applies despite some central operations at a fixed location)
United States v. Hines-Flagg, 789 F.3d 751 (7th Cir. 2015) (contrasting view that a consistent home base can preclude enhancement)
United States v. Thung Van Huynh, 884 F.3d 160 (3d Cir. 2018) (imposing enhancement where defendant returned home but traveled to commit fraud)