United States v. Carmon, No. 06-0165-cr (2d Cir. May 2, 2007) (found here)
Carmon appealed his sentence arguing that his intentional pre-sentence flight was not a sufficient basis for declaring that he had breached his plea and cooperation agreement. The Second Circuit responded with what seems obvious: (1) by absconding Carmon forfeited any rights he arguably may have had based on his cooperation agreement with the Government (including to the filing of a 5K1.1 letter); (2) intentionally failing to appear for sentencing is so inherently obstructive of the administration of justice that it -- standing alone -- is sufficient to support an obstruction of justice enhancement; and (3) intentionally failing to appear for sentencing constitutes a failure to accept responsibility for one's offense.
Some defendants . . . wow.