context: "[W]hen crimes involve 'indirect or secondary victims'," or where society at large is the victim, the crime is treated as a "victimless crime" for purposes of the grouping rules.
citation_a.signal: no signal
citation_a.identifier: 56 F.3d 536, 538-42
citation_a.parenthetical: affirming separate grouping of firearms offenses based on differences including place, time, nature of guns, and purposes of acts
citation_a.sentence: United States v. Bush, 56 F.3d 536, 538-42 (3d Cir.1995) (affirming separate grouping of firearms offenses based on differences including place, time, nature of guns, and purposes of acts). For such “victimless crimes”, “the grouping decision must be based primarily upon the nature of the interest invaded by each offense.”
citation_b.signal: see
citation_b.identifier: 960 F.2d 965, 967-69
citation_b.parenthetical: finding district court properly did not group two obstruction convictions for acts that arose out of same scheme but occurred two years apart and involved different harms-- one involved interfering with proper sentencing of another defendant, and the other involved attempt to suborn perjury before grand jury
citation_b.sentence: Id. at 538 (quotation and citation omitted); United States v. Riviere, 924 F.2d 1289, 1304 (3d Cir.1991); see Boggi, 74 F.3d at 473-74, 478-79 (district court separated racketeering and substantive counts of unlawful receipt of payments by union official into three groups based on different payors; ruling not challenged on appeal; circuit court approved of abuse of trust enhancements in all three groups but remanded for resentencing on other grounds); United States v. Beard, 960 F.2d 965, 967-69 (11th Cir.1992) (finding district court properly did not group two obstruction convictions for acts that arose out of same scheme but occurred two years apart and involved different harms— one involved interfering with proper sentencing of another defendant, and the other involved attempt to suborn perjury before grand jury).