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211855P.pdf   06/10/2022  United States  v.  Jonathan Montanez
   U.S. Court of Appeals Case No:  21-1855
   U.S. District Court for the District of North Dakota - Eastern   
[PUBLISHED] [Kobes, Author, with Colloton and Kelly, Circuit Judges] Criminal case - Sentencing. In this prosecution for civil disorder in violation of 18 U.S.C. Sec. 231(a)(3), the district court did not err in imposing an enhancement under Guidelines Sec. 2A2.4(a) for obstructing or impeding police officers, as this guidelines section was sufficiently analogous to defendant's conduct during the George Floyd civil disturbances. The district court did not err in determining this guidelines section was more analogous than Sec. 2B1.1(a)(2), which rests on property offenses rather than conduct intended to interfere with police officers in the performance of their duties.