New opinion

US v. McClure-Potts — criminal — affirmance — Greenaway

The Third Circuit today affirmed a criminal conviction for Social Security fraud, rejecting the defendant’s arguments that (1) she should have received a Sentencing Guidelines reduction for frauds committed “other than for profit” despite having received government benefits, (2) certain factual findings by the judge at sentencing were clearly erroneous, and (3) the court erred in calculating the loss amount used to set her Guidelines range.

Joining Greenaway were Ambro and Chagares. Arguing counsel were Fritz Ulrich of the MDPA federal defenders for the defendant and Stephen Cerutti of the MDPA US Attorney’s office for the government.