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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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