Where appellant's "offense of conviction" was the "failure to maintain an accurate oil record book while in U.S. waters," improper discharges that were not in U.S. waters are not "relevant conduct," and cannot be considered part of the "offense" under the U.S. Sentencing Guidelines, and the District Court erred in applying the six-level sentencing enhancement.
September 11, 2006 at 12:00 AM
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