Abstract
In United States v. Nygren , 933 F.3d 76 (1st Cir. 2019), Steven Nygren was found to be feigning cognitive limitations during an evaluation of competency to stand trial. He received an obstruction-of-justice sentence enhancement under the U.S. Sentencing Guidelines (USSG) § 3C1.1 (2014). Mr. Nygren
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