U.S. v. Brown, No. 93-5653 (4th Cir.) (23 F.3d 839) (May 5, 1994) (Judge John D. Jr. Butzner)
In this case, the district court found that the 1987 conviction involved a sale of only $ 20 worth of PCP, it decided that sentencing Brown as a career offender would overstate the seriousness of his criminal history. It relied on U.S.S.G. § 4A1.3, which authorizes downward departures when the …
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