United States v. Michael Iverson

GREGG COSTA, Circuit Judge:

Michael Iverson pleaded guilty to failure to register as a sex offender. He now challenges the length of his prison term and some of the conditions of his supervised release. The principal question his appeal raises is whether the Sentencing Guidelines’ obstruction-of-justice enhancement covers false statements made to obtain appointed counsel. We join the majority side of a circuit split in concluding that it does.

I

Iverson was required to register under the Sex Offender Registration and Notification Act because he had been convicted of rape and kidnapping in New…