United States v. Briggins

Briggins pleaded guilty in 2017 to committing multiple bank robberies. In 1999, he had been convicted of 10 bank robberies and sentenced to 84 months’ imprisonment. The number of criminal history points to be added for the 1999 robberies depended on whether that term reflected one sentence or multiple concurrent sentences. The PSR concluded that Briggins received 10 concurrent sentences but recognized that Briggins’s criminal history points needed to account for the reality that he was charged with all 10 robberies in the same indictment, pleaded guilty in the same proceeding, and faced sentencing on the same day and recommended that Briggins receive six criminal history points: three from USSG 4A1.1(a), which requires sentencing courts to “[a]dd 3 points for each prior sentence of imprisonment exceeding one year and one month” and three points from 4A1.1(e), which applies where a defendant is convicted of multiple offenses charged in the same indictment or receives multiple sentences on the same day and limits the maximum number of additional points to three. Applying 4A1.1(e) meant that only three additional points were allowed for Briggins’s nine robberies not encompassed by 4A1.1(a). The resulting advisory guidelines range was 77-96 months’ imprisonment. The Seventh Circuit affirmed his sentence of 96 months. View "United States v. Briggins" on Justia Law