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2022 Pepp. L. Rev. Ann. 1 (2022)

handle is hein.journals/pnelwrwan2022 and id is 1 raw text is: Defining Different-How Distinctive Methods of Textual Interpretation Led to the Abduction Enhancement Circuit Split Abstract This note examines thefederal circuit courts' differing approaches to in- terpreting the robbery abduction enhancement in the United States Sentenc- ing Guidelines. Specifically, this note setsforth how the Sixth Circuit's strict method of textual interpretation in United States v. Hill led to the erroneous holding that the term different location refers to aplace differentfrom the store that is being robbed. This note argues the court should have taken a more holistic interpretative approach, taking the underlying purpose of the Guidelines into account. 1

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