Three circuits have approved sentencing calculations under this guideline: In United States v. Smith, 231 F.3d 800, 818-21 (11th Cir. 2000), the Eleventh Circuit discussed the application of Section 2H2.1(a)(2) to a voter fraud scheme involving a deputy voter registrar and a political activist. The defendants were charged and convicted of multiple-voting (i.e., marking ballots in the names of voters without the voters’ knowledge) in violation of 52 U.S.C. § 10307(e), and forging voters’ names on applications for absentee ballots and on ballots in violation of 52 U.S.C. § 10307(c). Id. at 805-06. The Eleventh Circuit approved the following guideline calculations made by the district court: (1) a base offense level of twelve for both defendants; (2) a two-level enhancement for the deputy registrar for abuse of a position of public trust under U.S.S.G. § 3B1.3; (3) a four-level enhancement for both defendants based on the court’s finding that each was an “organizer or leader of criminal activity that involved five or more participants” under U.S.S.G. § 3B1.1(a); and (4) a two-level enhancement for the political activist for obstructing justice based on evidence that the defendant influenced a witness to give a false affidavit concerning material facts. Id. at 819-21. United States v. Cole, 41 F.3d 303 (7th Cir. 1994), also involved a deputy voter registrar who was convicted of multiple-voting in violation of 52 U.S.C. § 10307(e). Proof at trial established that the defendant applied for and marked absentee ballots for several voters without their knowledge and consent, and that he threatened one of these voters to dissuade him from cooperating in the ensuing criminal investigation. Id. at 308, 311. The district judge assigned a base offense level of twelve to the offense under Section 2H2.1(a)(2), and applied enhancements for the leadership role in a conspiracy involving five or more participants under Section 3B1.1(a) (four levels), abuse of a position of public trust under Section 3B1.3 (two levels), and 175

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