United States v. Augare, No. 14-30131 (Gould with Goodwin and Ikuta) --- The Ninth Circuit affirmed the application of an upward adjustment under the Guidelines for sophisticated means, in a case where the defendant pleaded guilty to conspiracy to defraud the United States.  This case involved fraud against an agency that provided services to an Indian community, and the district court did not abuse its discretion in concluding that the means by which he diverted the money from the service agency was intended to leave a complicated paper trail that made it difficult to uncover his fraud.

The decision is here:

http://cdn.ca9.uscourts.gov/datastore/opinions/2015/09/09/14-30131.pdf