United States v. Thompson

Defendant-Appellant Michael Thompson appeals his sentence following a jury trial and judgment of conviction. In this opinion, we address only Thompson’s objection to the decision of the United States District Court for the District of Connecticut (Burns, S.J.) to impose a two-level sentencing enhancement for obstruction of justice based on a recommendation in Thompson’s presentence report (“PSR”).1 Thompson contends that the district court erred by not making a finding of specific intent to obstruct justice. We agree.

BACKGROUND

On May 22, 2012, members of a Drug Enforcement Agency task force…