The following excerpt is from United States v. Lawani, 13-4574 (2nd Cir. 2014):
1. "On review of a district court's decision to enhance a defendant's sentence for obstruction of justice, we accept the court's findings of facts unless they are clearly erroneous." United States v. Pena, 751 F.3d 101, 105 (2d Cir. 2014) (per curiam) (internal quotation marks omitted). "We review de novo a ruling that the established facts constitute obstruction of justice, giving due deference to the district court's application of the guidelines to the facts." Id. (internal quotation marks omitted).
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