obstruction of justice under Section 3C1.1 (two levels), for a total offense level of twenty. Id. at 311. The defendant was sentenced to forty-six months of imprisonment. Id. at 305. The Seventh Circuit held that the district judge’s sentencing analysis was accurate. Id. at 311. In United States v. Haynes, Nos. 91-5979, 91-6076, 1992 WL 296782, at *1 (6th Cir. Oct. 15, 1992), the defendants, party officials authorized to register voters, were convicted of conspiracy against rights and deprivation of constitutional rights in violation of 18 U.S.C. §§ 241 and 242 by destroying over 150 voter registration applications. Starting with a base level of twelve, they received upward adjustments of two levels for abuse of a position of trust, and five levels for multiple counts, resulting in a total offense level of nineteen. Id. at *3-4. The trial court imposed sentences of thirty months of imprisonment. Id. at *2. The Sixth Circuit upheld these sentences with the exception of a twolevel reduction for the less culpable defendant. Id.at *3. Other election fraud convictions have resulted in similar calculations under the sentencing guidelines. E.g., United States v. Slone, 411 F.3d 643, 650-51 (6th Cir. 2005) (affirming defendant’s conviction for vote-buying in violation of 52 U.S.C. § 10307(c) and sentence of fifteen months’ imprisonment calculated on a base offense level of twelve under § 2H2.1(a)(2), plus a two-level enhancement for obstructing justice under § 3C1.1(b) for lying to the FBI); United States v. Sparkman, Cr. No. 99-30, 2008 WL 2787415, at *1 (E.D. Ky. July 12, 2000) (following conviction for vote- buying in violation of 52 U.S.C. § 10307(c) and lying to the FBI in violation of 18 U.S.C. § 1001, sentence of twenty-four months’ imprisonment calculated on a base offense level of twelve under § 2H2.1(a)(2), a three-level enhancement for leadership role under § 3B1.1(b), and two-level enhancement for obstruction of justice under § 3C1.1(b), for a total offense level of seventeen); United States v. Boards, Cr. No. 176