Whether the forced movement of victims from one room or area to another room or area within the same building constitutes an abduction for purposes of U.S.S.G. § 2B3.1(b)(4)(A)

QUESTIONS PRESENTED I. Whether the forced movement of victims from one room or area to another room or area within the same building constitutes an abduction for purposes of U.S.S.G. § 2B3.1(b) (4) (A) of the federal sentencing guidelines. (Notably, other circuits have addressed the question, and there is a split of authority). An important function of the Supreme Court is to resolve disagreements among lower courts about specific legal questions. A "split of authority" has developed over "whether the forced movement of victims from one room or area to another room or area within the same building constitutes an abduction for purposes of U.S.S.G. § 2B3.1(b) (4) (A)." United States v. Archuleta, 865 F.3d 1280, 1285 (10th Cir. 2020). Some courts hold that the customer area of a store or bank typically will not qualify as a "different" location from the back room or vault area of that store or bank. See United States v. Whatley, 719 F.3d 1206, 1221-23 (llth Cir. 2013); United States v. Eubanks, 593 F.3d 645, 652-654 (7th Cir. 2010); see also Archuleta, 865 F.3d at 1292-95 (Seymour, J., concurring in part and dissenting in part); United States v. Reynos, 680 F.3d 283, 292-96 (3d Cir. 2012) (Ambro, J., dissenting). Others hold that any different "position" in a building counts as a "different location." Archuleta, 865 F.3d at 128588; see United States v. Buck, 847 F.3d 267, 276-77 (5th Cir. 2017); Reynos, 680 F.3d at 289-91; United States v. Osborne, 514 F.3d 377, 389-90 (4th Cir. 2008). This court should grant certiorari to resolve the circuit split because the proper application of U.S.S.G.§ B3.1(b) (4) (A), is of exceptional i importance to the administration of ' justice in federal criminal cases. i aa