United States v. Shonda Stubblefield, 942 F.3d 666

Stubblefield ran a fraudulent telework program and received nearly $126,000 from H‑GAC, which distributed federal grant funds from TDOT.
A TDOT reviewer flagged a submission in 2014; H‑GAC audited Stubblefield, requested personnel files, and she produced false documents and withheld files.
H‑GAC cancelled the grant; TDOT referred the matter to federal authorities, leading to indictment and conviction for mail/wire fraud, theft of public money, aggravated identity theft, and unlawful monetary transactions.
The PSR applied a two‑level obstruction enhancement under U.S.S.G. § 3C1.1 for providing false documents to an "official investigation;" Stubblefield objected, arguing the H‑GAC audit was not a governmental investigation.
The district court overruled the objection, imposed a 72‑month sentence, and Stubblefield appealed only the § 3C1.1 enhancement.
The Fifth Circuit affirmed, concluding it was plausible Stubblefield believed a state or federal investigation was underway or would be, so the enhancement was properly applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3C1.1 two‑level obstruction enhancement applies for obstructing an H‑GAC audit by producing false documents	H‑GAC audit was not a governmental or "official" investigation, so § 3C1.1 does not apply	§ 3C1.1 applies where defendant willfully obstructed an investigation she believed was or would be governmental; belief suffices even for pre‑investigation conduct	Affirmed — plausible from the record that Stubblefield believed a state or federal investigation was probable, so enhancement proper

United States v. Gharbi, 510 F.3d 550 (5th Cir. 2007) (standard of review: facts for clear error, Guidelines interpretation de novo)
United States v. Adam, 296 F.3d 327 (5th Cir. 2002) (factual findings plausible on whole record are not clearly erroneous)
United States v. Alexander, 602 F.3d 639 (5th Cir. 2010) (post‑2006 § 3C1.1 language focuses on obstruction with respect to investigation/prosecution/sentencing)
United States v. Lister, 53 F.3d 66 (5th Cir. 1995) (pre‑2006 rule required defendant’s knowledge or correct belief an investigation was underway)
United States v. Brooks, 681 F.3d 678 (5th Cir. 2012) (post‑2006 precedent allows consideration of pre‑investigation conduct under § 3C1.1)