United States v. Williams, 627 F.3d 839

Williams was charged in a three-count indictment for forcibly assaulting U.S. Marshals and pled guilty to one count, later withdrawing his plea.
At trial, Williams testified he believed his pursuers were carjackers, not federal marshals, and disputed the officers' identification and actions.
The jury found Williams guilty on two charges and found an enhancement for use of a deadly weapon against one marshal.
The presentence report recommended a three-point acceptance of responsibility reduction and classified Williams as a career offender, for a guideline range of 151–188 months.
The district court granted a two-point acceptance reduction and declined to enhance for obstruction; it ultimately sentenced Williams to 120 months after a downward variance.
On appeal, the government argues error in the acceptance reduction and in failing to enhance for obstruction; Williams cross-appeals relevant issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instruction was plain error	Williams contends the court directed the jury to find knowingly and willfully.	Williams argues the instruction improperly framed the mental state requirement.	No plain error; instruction correctly stated the standard.
Whether the district court erred in reducing by acceptance of responsibility	Williams contends he accepted responsibility and the reduction was proper.	Government argues Williams denied guilt at trial and thus cannot merit the reduction.	District court erred; reduction should not have been applied.
Whether Williams' sentence should be enhanced for obstruction of justice	Williams testified he did not intend to obstruct and that perjury was not established.	Government argues perjury was proven and warrants enhancement.	District court erred by not applying the obstruction enhancement; remand for resentencing.

United States v. Amedeo, 370 F.3d 1305 (11th Cir. 2004) (clear error standard for acceptance of responsibility and obstruction findings)
United States v. Bradberry, 466 F.3d 1249 (11th Cir. 2006) (standard on obstruction of justice and related factual findings)
United States v. Felts, 579 F.3d 1341 (11th Cir. 2009) (plain-error review for challenged jury instructions)
United States v. Rubio, 317 F.3d 1240 (11th Cir. 2003) (denial of acceptance of responsibility when pleading guilty and then testifying contrary)
United States v. Geffrard, 87 F.3d 448 (11th Cir. 1996) (perjury under oath on material matters justifies obstruction enhancement)
United States v. Poirier, 321 F.3d 1024 (11th Cir. 2003) (perjury and obstruction discussed in sentencing context)
United States v. Barner, 572 F.3d 1239 (11th Cir. 2009) (remedial resentencing when guideline miscalculation occurred)