U.S. v. Catucci, No. 94-1195 (1st Cir.) (55 F.3d 15) (May 24, 1995) (Judge Conrad K. Cyr)
Case held that a downward departure based on aberrant behavior unless the crime was a spontaneous and seemingly thoughtless act rather than one which was the result of substantial planning.
This case is noted because it discusses [in note 3] the concept of "aberrant behavior" as a grounds for departure …
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