United States v. Quirion
2013 U.S. App. LEXIS 8724
| 1st Cir. | 2013Background
- District court concluded Quirion obstructed justice by lying to federal agents to protect Mancos.
- Three-count indictment; charges included marijuana distribution and felon-in-possession; Quirion pleaded guilty to counts 1 and 3.
- Dispositional hearing set base offense level 14 with three enhancements, yielding an adjusted level 22 and methent (sic) guideline 77-96 months; imposed 80-month sentence.
- Quirion argued the obstruction enhancement was improper; the court found he willfully lied and that statements impeded investigation and prosecution.
- Record shows multiple interviews in 2010-2011 where Quirion claimed inheritance of long guns; later claimed pawn transaction; discrepancies prompted PSI amendments and hearings.
- On appeal, the First Circuit upheld the obstruction-of-justice enhancement as supported by material false statements significantly impeding the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the obstruction enhancement was properly applied | Government argues statements were material and impeded investigation. | Quirion argues statements were immaterial or not obstruction. | Obstruction enhancement affirmed; material false statements significantly impeded. |
Key Cases Cited
- United States v. Rodriguez, 336 F.3d 67 (1st Cir. 2003) (burden of proof and standard for obstruction analysis)
- United States v. Aymelek, 926 F.2d 64 (1st Cir. 1991) (preponderance-standard for obstruction)
- United States v. Gates, 709 F.3d 58 (1st Cir. 2013) (reliability of sentencing evidence and factual findings)
- United States v. Cintrón-Echautegui, 604 F.3d 1 (1st Cir. 2010) (scope of materiality in obstruction analysis)
- United States v. Restrepo, 53 F.3d 396 (1st Cir. 1995) (materiality standard for obstruction)
- United States v. U.S. Gypsum Co., 333 U.S. 364 (S. Ct. 1948) (defining standard of review for factual findings)
- United States v. Thomas, 86 F.3d 263 (1st Cir. 1996) (costly investigations prompted by false statements)
- United States v. Grigsby, 692 F.3d 778 (7th Cir. 2012) (examples of obstruction of justice cases)
- United States v. St. Cyr, 977 F.2d 698 (1st Cir. 1992) (credibility determinations at sentencing)