Warren: Guideline enhancement requires only one obliterated serial number

In U.S. v. Warren, No. 15-12519 (April 21, 2016), the Court affirmed the imposition of a four-level enhancement under U.S.S.G. § 2K2.1(b)(4)(B), for possession of a firearm that had an altered or obliterated number. When Warren was arrested the serial number on the gun’s frame was intact, while the serial number on its slide had been altered or obliterated. The Court held that the enhancement applied even when only one of two serial numbers had been altered or obliterated. The Court relied on the plain language of the Guideline, which only required that the firearm had “an” altered or obliterated serial number.