Is there any case law supporting a finding that there is no case law in favour of establishing that there was independent, unforeseeable criminal misconduct of a third party?

MultiRegion, United States of America

The following excerpt is from United States v. Lloyd, No. 12-50499, No. 12-50500, No. 12-50509, No. 12-50514, No. 12-50526, No. 12-50566 (9th Cir. 2015):

independent, and unforeseeable criminal misconduct of a third party," United States v. Hicks, 217 F.3d 1038, 1049 (9th Cir. 2000), or by the vagaries of the movie-watching public. The record supports the district court's conclusion that Greenhouse was a causal factor in his victims' losses and did not err in applying the loss enhancement.

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