U.S. v. Washington, No. 93-50786 (9th Cir.) (66 F.3d 1101) (October 4, 1995) (Judge Stephen Reinhardt)
Court holds that a 1991 amendment to § 2J1.2 (which permitted application of a cross-reference to a defendant who was not an accessory - was a substantive amendment - not a clarifying one - and therefore could not be applied retroactively.
This case vacates a sentence that was based on …
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