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This document summarizes a court case regarding the sentencing of Robert Landmesser for theft of anhydrous ammonia. The District Court applied a two-level sentencing enhancement under USSG 2D1.12(b)(2) for unlawful discharge of a hazardous substance, based on vapor from the stolen tanks burning Landmesser. However, the Court of Appeals found that for the enhancement to apply, the discharge must violate environmental statutes listed in the guideline

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Scribd Government Docs

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EN