What is the current state of the law on sentencing enhancements for physical restraint and injury to victim?

MultiRegion, United States of America

The following excerpt is from United States v. Graham, No. 14-4037-cr (2nd Cir. 2015):

multiple 2B3.1 sentencing enhancements for physical restraint and injury to victim where conduct found to "facilitate, as opposed to constitute" offense); accord United States v. Sabhnani, 599 F.3d 215, 251 (2d Cir. 2010) (stating that "[m]ultiple adjustments are properly imposed . . . when they aim at different harms emanating from the same conduct" (internal quotation marks omitted)).

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