United States v. Steven B. Zats
Court of Appeals for the Third Circuit
1Opinion of the Court
OPINION OF THE COURT
AMBRO, Circuit Judge.
Steven Zats used his debt collection practice to defraud creditors who hired him. After he was caught, he pled guilty to several federal offenses. In this appeal, Zats contends that the District Court erred by enhancing his sentence pursuant to § 3Al.l(b) of the United States Sentencing Guidelines (“U.S.S.G.”), better known as the vulnerable victim enhancement. We affirm.
I. Factual and Procedural History
Zats was an attorney who specialized in collecting small debts, usually hundreds of dollars. Many of his clients were doctors whose patients owed money…
2Cases cited14 opinions
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