LR-92-183 (E.D. Ark. Sept. 12, 1994) (sentencing proceeding) (following convictions for conspiracy and providing false information under § 10307(c); total offense level of eight; prison term of thirteen months imposed), 10 F.3d 587 (8th Cir. 1993) (reversing trial court’s judgments of acquittal on several counts and affirming other convictions); United States v. Salisbury, Cr. No. 2-90-197 (S.D. Ohio Oct. 8, 1991) (sentencing proceeding) (conviction for multiple-voting in violation of 52 U.S.C. § 10307(e); total offense level of fourteen; prison term of eighteen months imposed), rev’d on other grounds, 983 F.2d 1369 (6th Cir. 1993) (statute unconstitutionally vague as applied to defendant's conduct). The Smith and Cole cases illustrate several issues prosecutors are likely to face in this area. First, all the defendants received four-level enhancements for their role in the offenses. In Cole, the defendant had contended that the fifteen voters involved were victims of the conspiracy, not “participants” within the meaning of Section 3B1.1. The court agreed with the government that, regardless of whether the voters were participants or outsiders, the criminal activity was “otherwise extensive" within the meaning of Section 3B1.1(a). In addition, both district courts found that a deputy voter registrar occupied a position of trust, requiring a two-level increase under Section 3B1.3. The Sixth Circuit also approved this upward adjustment in Haynes. The Smith case presented another important sentencing issue. The defendants argued that the offense was essentially a “multiple-voting” crime, and the appropriate base level for “multiple-voting” was six under Section 2H2.1(a)(3) rather than twelve under Section 2H2.1(a)(2). Their argument was based on the fact that the words “multiple- voting” appear in Section 2H2.1(a)(3). The Eleventh Circuit held that despite this specific reference, Section 2H2.1(a)(3) was intended to apply only to isolated instances of electoral fraud (e.g., one person voting 177