United States v. Redman, 887 F.3d 789

Scott Redman, a high-school dropout, posed as Dr. Julian Lopez Garcia and was hired as a psychiatrist at Clarity Clinic in Chicago (Sept. 2015–Feb. 2016). He used fake diplomas, licenses, and identity documents and obtained a DEA registration in the real doctor's name.
He treated patients and issued about 92 prescriptions for controlled substances to 57 patients despite lacking medical training; some prescriptions and diagnoses were medically inappropriate.
The real Dr. Garcia discovered misuse of his Illinois medical license number; Redman was indicted on wire fraud, aggravated identity theft, false statements in DEA application, and controlled-substance distribution charges and convicted on all counts.
The presentence report grouped counts, applied several enhancements, and calculated a combined adjusted offense level of 31, criminal-history category II, yielding a Guidelines range of 121–151 months plus a mandatory consecutive two-year term for aggravated identity theft.
At sentencing the district court adopted the PSR, imposed a 157‑month sentence, and applied two disputed two-level enhancements: (1) sophisticated means under U.S.S.G. § 2B1.1(b)(10)(C) and (2) conscious/reckless risk of death or serious bodily injury under U.S.S.G. § 2B1.1(b)(15)(A).

Issue	Redman’s Argument	Government/District Court Argument	Held
Whether § 2B1.1(b)(10)(C) sophisticated-means enhancement applies	Scheme not more complex than typical fraud; used unsophisticated counterfeit websites; short duration	Created extensive fabricated paperwork, fake credentials, government filings to obtain DEA number; conduct showed planning/concealment	Affirmed — enhancement appropriate; scheme was sufficiently sophisticated
Whether § 2B1.1(b)(15)(A) risk-of-serious-injury enhancement applies	No proof of actual serious injury; argued he could prescribe safely despite lack of training; reliance on historical absence of licensing is irrelevant	Patients with serious psychiatric conditions relied on untrained impostor; misprescribing risks addiction, overdose, misdiagnosis leading to serious harm or death	Affirmed — court reasonably found conduct created conscious/reckless risk of death or serious bodily injury

United States v. Fletcher, 763 F.3d 711 (7th Cir. 2014) (standard: de novo review of Guidelines interpretation; clear-error review of factual findings)
United States v. Wayland, 549 F.3d 526 (7th Cir. 2008) (clear-error standard for sophisticated-means finding)
United States v. Vivit, 214 F.3d 908 (7th Cir. 2000) (application of risk-of-serious-injury enhancement in medical-prescription context)
United States v. Ghaddar, 678 F.3d 600 (7th Cir. 2012) (sophisticated-means requires greater planning/concealment than typical fraud)
United States v. Anobah, 734 F.3d 733 (7th Cir. 2013) (example of sophisticated document-based fraud scheme)
United States v. Allan, 513 F.3d 712 (7th Cir. 2008) (broad view of conduct that may be "sophisticated")
United States v. Rettenberger, 344 F.3d 702 (7th Cir. 2003) (sophistication where defendants used falsified documents to deceive professionals and agencies)
United States v. Wu, 81 F.3d 72 (7th Cir. 1996) (analogous sophistication finding in fraud involving false names and records)
United States v. Jimenez, 41 Fed.Appx. 1 (7th Cir. 2002) (prescription misconduct can support risk-of-serious-injury enhancement)