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U.S. v. Windle, No. 95-8008 (10th Cir.) (74 F.3d 997) (January 22, 1996) (Judge Wade Brorby)

The commentary to § 4A1.2 of the Guidelines permits the use of prior "uncounseled misdemeanor sentences" to increase a defendant's Criminal History Category, even where imprisonment was not imposed. In this case, the defendant waived his right to counsel at the time he was convicted of those prior misdemeanors. The …

 

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