The United States Court of Appeals for the Eighth Circuit has issued an opinion in a North Dakota case.
In United States v. Montanez, the court held that, in this prosecution for civil disorder in violation of 18 U.S.C. Sec. 231(a)(3), the district court did not err in imposing an enhancement under Guidelines Sec. 2A2.4(a) for obstructing or impeding police officers, as this guidelines section was sufficiently analogous to defendant's conduct during the George Floyd civil disturbances. The court held that the district court did not err in determining this guidelines section was more analogous than Sec. 2B1.1(a)(2), which rests on property offenses rather than conduct intended to interfere with police officers in the performance of their duties.
Read the court's opinion at: http://media.ca8.uscourts.gov/opndir/22/06/211855P.pdf