U.S. v. Thomas, No. 93-1813 (2nd Cir.) (54 F.3d 73) (April 21, 1995) (Judge Amalya Lyle Kearse)
This case reverses Judge Raggi's decision to increase a defendant's Criminal History Category under § 4A1.2 of the Guidelines by using prior convictions based on conduct that was part of the instant offense. That is not allowed. The prior convictions can be considered as part of "relevant conduct" under § …
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