Section 4.5.6

4.5.6. Further Guidance.As often observed, the scope of the project rule may “be stated easily enough” but “is not so easily understood or applied.”707 For further guidance, the two major Supreme Court decisions on the scope of the project rule are United States v. Miller and United States v. Reynolds.708 The Fifth Circuit’s influential opinion in United States v. 320 Acres analyzes applications of the rule as well as its historical and legal origins.709 Two more recent cases on the applicability of the scope of the project rule are also instructive: United States v. 480.00 Acres (Fornatora), from the Eleventh Circuit, and United States v. 1.604 Acres (Granby I), from the Eastern District of Virginia.710