United States v. Paul Savas Columbus

Appellant Paul Savas Columbus pled guilty to two counts of smuggling semiconductors into the United States in violation of 18 U.S.C. § 545 . Columbus now challenges the district court’s denial of his motions to amend certain alleged factual inaccuracies in his presentence report. We affirm.

I.

Based on a preliminary determination that Japanese-made semiconductors were being sold in the United States at less than fair value, the United States Department of Commerce in March 1986 imposed a provisional import tariff on dynamic random access memory semiconductors of 256 kilobits (“256K DRAMs”) and above. These trade restrictions drastically affected the United States market for 256 DRAMs. — Supplies of semiconductors in the United States grew increasingly scarce, while domestic customer demand for these products continued unabated. Such market forces prompted many to circumvent the trade regulations and tariffs on 256 DRAMs by smuggling Japanese-made chips into the United States for sale on the domestic market. On August 7,1986, the United States Department of Commerce suspended its antidumping duty investigation on Japanese-made 256K DRAMs and ordered refunds for cash deposits or…