Epstein Secrets

andgraf v. USI Film Products, 511 U.S. 244 (1994) Leocal v. Ashcroft, 11 passim 543 U.S. 1 (2004) 11 Martin v. Hadix, 527 U.S. 343 (1999) 6 Nijhawan v. Holder, 557 U.S. 29 (2009) 12, 13 Shular v. United States, 140 S. Ct. 779 (2020) 11, 14 Toussie v. United States, 397 U.S. 112 (1970) 8, 9

and referring only to the intent of the amendment generally), cert. denied, No. 20.5064, S.Ct. —, 2021 WL 78235 (Jan. 11, 2021); United States v. Leo Sure Chief 438 F.3d 920, 924 (9th Cir. 2006) (discussing only the intent of the amendment generally); United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir.

the government cites in which the Court applied a fact-based approach to an "offense involving" statute—does not break this line of cases at all. In Nijhawan, the statutory provision at issue referred to "an offense that . . . involves fraud or deceit in which the loss to the victim or victims exceeds $1

t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an

ions of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz v. Maypa, 773 F.3d 138, 145 (4th Cir. 2014); United States v. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir. 2006). The Supreme Court has set out a two-step framework to determine whether a federal statute applies to past cond

t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an

ions of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz v. Maypa, 773 F.3d 138, 145 (4th Cir. 2014); United States v. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir. 2006). The Supreme Court has set out a two-step framework to determine whether a federal statute applies to past cond

t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an

ions of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz v. Maypa, 773 F.3d 138, 145 (4th Cir. 2014); United States v. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir. 2006). The Supreme Court has set out a two-step framework to determine whether a federal statute applies to past cond