United States v. Eric Flores, 974 F.3d 763

Inmate Eric Flores participated in a multi-stabber attack inside federal prison; the victim was stabbed at least six times with prison-made shanks.
Guards observed the victim shouting for help, bleeding through clothing, and worrying he was dying; photos and eyewitnesses corroborated heavy bleeding and visible wounds.
Hospital CT scans showed a fractured left scapula from a puncture, deep bruising from internal bleeding, and subcutaneous air pockets; lab results indicated significant blood loss.
Doctors performed five laceration repairs, including multi-layer (two-layer) sutures, administered IV antibiotics prophylactically (sepsis risk from non-sterile shanks), and gave narcotic pain medication; victim reported pain 6–8/10.
At trial the victim testified for the defense and characterized injuries as minor; Flores was nevertheless convicted of assault with a dangerous weapon and the district court applied a five-level enhancement under U.S.S.G. §2A2.2(b)(3)(B) for "serious bodily injury," sentencing Flores to 110 months.
On appeal the Sixth Circuit affirmed, holding the enhancement was supported by extreme pain and medical intervention (sutures/surgery) and that the district court permissibly discounted the victim’s defense testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the §2A2.2(b)(3)(B) five-level enhancement for "serious bodily injury" was proper	Flores: victim testified injuries were minor and superficial, so enhancement not warranted	Government: objective medical evidence (CT fracture, blood loss labs), multi-layer sutures, IV meds, and narcotic pain control show extreme pain and medical intervention	Affirmed: enhancement proper—victim suffered extreme pain and required medical intervention (sutures/surgery); court reasonably discounted victim’s testimony

United States v. Thomas, 933 F.3d 605 (6th Cir. 2019) (discusses standard of review for Guidelines application)
United States v. Havis, 927 F.3d 382 (6th Cir. 2019) (en banc) (court must follow commentary interpretation of Guidelines)
Encino Motorcars, LLC v. Navarro, 138 S. Ct. 1134 (2018) (interpreting disjunctive "or" in statutory lists)
United States v. Clay, [citation="90 F. App'x 931"] (6th Cir. 2004) (sutures/medical intervention can qualify as serious bodily injury)
United States v. Corbin, 972 F.2d 271 (9th Cir. 1992) (two-layer suture closure qualifies as surgery for enhancement)
United States v. Le, [citation="178 F. App'x 386"] (5th Cir. 2006) (upholding enhancement where stabbing caused significant blood loss, pain, and required multi-layer sutures)