US v. Carter
No. 03-10377 (8-25-05). In a firearms case, the 9th addresses a guideline issue: what does it mean to have an "altered or obliterated" firearm serial number. If a serial number is altered, there is a two level increase under 2K2.1(b)(4). The 9th defines "altered or obliterated" as being materially changed in a way that makes accurate information less accessible. The 9th further states that a serial number that is not discernible by the naked eye, but remains detectable via microcopy, is altered or obliterated. This is supported by the First Circuit's interpretation in Adams.