United States v. Jeffrey Woronowicz, 744 F.3d 848

Woronowicz challenges a 41-month sentence after pleading guilty to a one-count counterfeiting indictment under 18 U.S.C. § 474.
In 2008 he was convicted of four counts of willful failure to file tax returns and sentenced to 12 months; additional 3 months for supervised release violations followed.
Authorities found counterfeit currency exceeding $207,000 at his residence, with most bills incomplete and materials to manufacture counterfeit currency.
The District Court applied a 12-level enhancement under § 2B5.1(b)(1)(B) based on face value exceeding $200,000; the court rejected a no-enhancement argument due to incomplete bills.
Total offense level was 20 with criminal history IV, yielding a Guidelines range of 51–63 months; the court varied downward to 41 months, citing the incompleteness of many bills as mitigating.
The court explained the downward variance and considered but weighed against mitigation factors, including the currency being produced decades earlier.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether incomplete bills count toward face value under § 2B5.1(b)(1)(B).	Woronowicz argues incomplete bills should not be counted.	Woronowicz contends the government errs by including incomplete bills in face value.	Incomplete bills count toward face value under § 2B5.1(b)(1)(B).
Whether the face-value calculation relied on cross-referenced notes is correct under Lamere/ Taftsiou guidance.	Woronowicz challenges application notes limiting notes’ reach.	Woronowicz’s approach is consistent with interpretations allowing notes to count toward face value.	Notes may be counted toward face value under § 2B5.1(b)(1) as extended by Lamere/ Taftsiou.
Whether the sentence is procedurally and substantively reasonable under § 3553(a).	Woronowicz argues the court failed to meaningfully consider § 3553(a) factors and provide reasons.	Woronowicz argues the district court did consider factors and varied downward appropriately.	Sentence within the bottom of the Guidelines range with a two-level downward variance was reasonable and not an abuse of discretion.

United States v. Wright, 642 F.3d 148 (3d Cir. 2011) (face-value enhancement analysis for § 2B5.1(b)(1)(B))
United States v. Lamere, 980 F.2d 506 (8th Cir. 1992) (interpretation of note 3 in § 2B5.1 and counting one-sided bills)
United States v. Taftsiou, 144 F.3d 287 (3d Cir. 1998) (limited reach of note 3 to cross-referenced subsection (b)(2))
United States v. Cho, 136 F.3d 982 (5th Cir. 1998) (distinguishes § 2B5.1 cross-reference issues (irrelevant here))
United States v. Kelly, 204 F.3d 652 (6th Cir. 2000) (counting incomplete/uncleared bills under face value)
United States v. Webster, 108 F.3d 1156 (9th Cir. 1997) (counting uncut bills under face value)
United States v. Ramacci, 15 F.3d 75 (7th Cir. 1994) (counting one-sided bills under face value)
United States v. Ross, 844 F.2d 187 (4th Cir. 1988) (statutory context for § 472 vs § 474 and currency imitation)
United States v. Olfano, 503 F.3d 240 (3d Cir. 2007) (abuse of discretion standard for sentence)
United States v. Tomko, 562 F.3d 558 (3d Cir. 2009) (abuse-of-discretion review of sentence within guidelines)
United States v. Dragon, 471 F.3d 501 (3d Cir. 2006) (plain-error review for sentencing arguments raised on appeal)