“(U.S. 6th Cir., Feb. 5, 2008) – Defendants’ sentences resulting from their clumsy robbery of rare books from a university and attempts to sell them at auction are vacated and remanded for re-sentencing, where the district court erred by excluding books dropped and abandoned in the library stairwell from the valuation of loss and computation of the sentencing range. The court held that the defendant-robbers “took” the books, under USSG, 2B3.1, when they exercised dominion and control over them, such that they completed the acts necessary to seize the books.”
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