United States v. Shumway
United States v. Shumway, 112 F.3d 1413 (10th Cir. 1997).
The Court of Appeals for the Tenth Circuit upheld the conviction of Earl Shumway for violating the Archaeological Resources Protection Act (“ARPA”), damaging U.S. property, and possessing a firearm, in connection with his illegal excavations of Native American sites on federal land in Utah. Determining that the ordinary measure of loss, as calculated by the