United States v. Martin Rothman

DUHÉ, Circuit Judge.

Defendant Martin Rothman contends that in determining his sentence, the district court erred by failing to apply the three-level reduction available to a conspirator arrested before the completion of the offense. Because we consider the degree of completion of the underlying offense, and not of the conspiracy itself, to be the relevant inquiry, we vacate the sentence and remand to the district court for resen-tencing.

Two co-defendants, Joseph Hillner and Charles Howell, initiated a conspiracy to launder money that a third party claimed he had earned through illegal drug…