In United States v. Adeleke, 968 F.2d 1159 (11th Cir. 1992), a noncitizen who had been convicted of illegal reentry also challenged his 2L1.2 sentence enhancement on equal protection grounds. He argued that because criminal history adjustments already take a defendant's prior criminal history into account, 2L1.2 effectively punishes illegal reentrants, and not citizens, twice for the same crime. Id. In rejecting this argument, the Eleventh Circuit noted that the enhancement properly implements the legitimate government interest in deterring the reentry of deported felons: "The Sentencing Commission may have concluded that an alien who has been convicted of a felony should be strongly deterred from re-entering the United States, a consideration not present with respect to an American citizen." Id.