United States v. Brown (P)

After the defendant pleaded guilty to possession of a firearm by a convicted felon, the district court did not err in adding two points to his criminal history score based on a prior Virginia state conviction for which he received a suspended sentence conditioned upon good behavior. A suspended sentence in Virginia conditioned on a period of good behavior is a criminal justice sentence for purposes of U.S. Sentencing Guidelines § 4A1.1(d).

Affirmed.

United States v. Brown (P), No. 17-4745, Nov. 29, 2018. 4th Cir. (Diaz) from EDVA at Newport News (Jackson).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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