United States v. Baptiste

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Defendant appealed his 41-month sentence after he pleaded guilty to two federal crimes. The Eleventh Circuit held that where, as here, a defendant has pleaded guilty to a prior crime and adjudication has been withheld, that disposition must be counted for a single criminal-history point under USSG 4A1.1(c), regardless of whether the sentencing court purported to impose—or even actually imposed—198 days or no days of imprisonment. Accordingly, the court vacated defendant's sentence and remanded for resentencing. View "United States v. Baptiste" on Justia Law