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Criminal—Conviction without lawyer counts toward sentence (access required)

A 30-day sentence imposed after a defendant validly waived his right to counsel on a misdemeanor charge was properly included in the calculation of defendant’s criminal history score under the Sentencing Guidelines. Background On Aug. 8, 2017, a federal grand jury returned a four-count indictment charging Justin Tyme Hawley with two counts of possessing a firearm after ...

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