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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
OGHENEVWAKPO IGBOBA,
Defendant-Appellant.
   No. 19-1116
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:17-cr-00044-1—Robert J. Jonker, District Judge.
Decided and Filed: July 2, 2020
Before: COLE, Chief Judge; CLAY and NALBANDIAN, Circuit Judges.


_________________________
OPINION
_________________________

CLAY, CIRCUIT JUDGE. A jury convicted Defendant Oghenevwakpo Igboba on multiple criminal counts based on his participation in a conspiracy to defraud the United States Department of the Treasury by preparing and filing false federal income tax returns using others’ identities. Defendant was subsequently sentenced to 162 months’ imprisonment, followed by three years of supervised release, and required to pay restitution, special assessment, and forfeiture sums.

Defendant challenges that sentence on appeal, presenting two primary arguments. First, he argues that when the district court increased his base offense level based on the total amount of loss his offense caused, pursuant to U.S.S.G. § 2B1.1(b)(1), it failed to distinguish between the loss caused by his individual conduct and that caused by the entire conspiracy. Second, Defendant asserts that the district court erred in applying a two-level sophisticated-means enhancement, id., § 2B1.1(b)(10), because the means he used did not qualify as sophisticated.

For the reasons set forth below, we AFFIRM the district court’s decision.



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SAWARIMEDIA, LLC; DEBORAH PARKER; JUDY KELLOGG; PAUL ELY,
Plaintiffs-Appellees,
v.
GRETCHEN WHITMER, Governor of Michigan; JOCELYN BENSON, Secretary of State of Michigan; JONATHAN BRATER, Director of the Michigan Bureau of Elections,
Defendants-Appellants.
   No. 20-1594
Appeal from the United States District Court
for the Eastern District of Michigan at Flint.
No. 4:20-cv-11246—Matthew F. Leitman, District Judge.
Decided and Filed: July 2, 2020
Before: NORRIS, CLAY, and LARSEN, Circuit Judges.


_________________________
ORDER
_________________________

This appeal is another in a series of cases concerning the interaction between several states’ stay-at-home orders and the signature requirements needed to gain access to the ballot.

. . .

For the reasons stated above, Defendants’ motion for a stay pending appeal is denied. We retain jurisdiction over this appeal but direct the district court to address any further remedy proposed by Defendants by no later than July 15, 2020. If Defendants fail to propose a remedy that resolves the constitutional infirmity by that date, they will be precluded from enforcing the petition deadline against Plaintiffs, pending further review of any proposed remedy by this Court.