Hassan Abbas v. United States

Has the First Circuit impermissibly relied on a sentencing guideline application note's caption to override its own unqualified text? Does "referenced to" a sentencing guideline under USSG § 2B1.1 sweep in offenses only indirectly connected to it, as the First Circuit held? May a court treat "personally causing" a victim's financial hardship as satisfied by mere participation in the scheme that caused it? Did the First Circuit misapply the wire-fraud statute by reaching a transaction whose fraud, victim, and perpetrators were all located abroad?