offense levels under Section 3B1.3. U.S.S.G. § 2H2.1, cmt. background (1998). • If individual voters are viewed as vulnerable victims, separate substantive counts under Section 2H2.1 generally cannot be grouped under Section 3D1.2, so that counts involving multiple voters may result in increases of up to an additional five levels. • Obstruction may add increased levels under Section 3C1.1. See Slone, 411 F.3d 643 (lying to the FBI); Cole, 41 F.3d 303 (threatening a witness). • If the election fraud involved “corrupting a public official,” an upward departure may be warranted under Chapter Five, Part K (Departures). U.S.S.G. § 2H2.1, cmt. n.1 (1998). Thus, even for defendants without a criminal history, the guidelines’ upward adjustments generally raise the base offense level for election fraud to a point where the imposition of significant prison terms is recommended. For the purpose of sentencing criminal violations of FECA, offenses are handled under FECA guidelines. The guideline, U.S.S.G. § 2C1.8, reads as follows: 179

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