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United States v. Christianson

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ARGUED SEPTEMBER 24, 2009

Before POSNER, MANION, and TINDER, Circuit Judges.

In the summer of 2000, defendants Katherine Christianson and Bryan Rivera were members of the Earth Liberation Front, identified by the FBI as a domestic eco-terrorist group. Besides attending meetings and protests, they also found time to destroy several research projects at a U.S. Forest Service facility in Rhinelander, Wisconsin. They were not prosecuted until eight years later when they were indicted for and pleaded guilty to destroying government property. The district court sentenced Christianson to 24 months’ and Rivera to 36 months’ imprisonment respectively; both sentences were substantially lower than the recommended guideline range but the government does not contest them. On appeal, the defendants challenge the district court’s loss-amount calculation; Rivera also argues that the district court erred in applying the terrorism enhancement. We affirm.

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