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U.S. v. Brock, No. 96-4405 (4th Cir.) (108 F.3d 31) (February 28, 1997) (Judge William W. Jr. Wilkins)

Here, based largely on Koon v. U.S., the Fourth Circuit re-evaluated its former position and held that post-offense rehabilitation efforts may justify a downward departure - but see USSG ยง 5K2.19 which became effective on Nov. 1, 2000.

This could be an extremely important departure decision under the Guidelines. Until ...

 

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