How has section 5K2.3 of the Criminal Code been interpreted in the context of psychological injury suffered by the victim's family?
MultiRegion, United States of America
The following excerpt is from U.S. v. Haggard, 41 F.3d 1320 (9th Cir. 1994):
Our analysis begins with United States v. Hoyungowa, 930 F.2d 744 (9th Cir.1991). In that case, we held that section 5K2.3 applies only to the "direct victims" of the charged offense. Id. at 747. We reversed an upward departure made on the basis of the psychological injury suffered by the family of a murdered federal officer, because the family
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