U.S. v. Delgado-Reyes, No. 99-2121 (1st Cir.) (245 F.3d 20) (March 29, 2001) (Judge Frank M. Coffin)
Recently we have seen a number of cases that have emphasized a distinction between “horizontal” and “vertical” departures under the Guidelines. Most of those cases have raised the issue in the context of waivers of appeal rights: when a defendant agrees in a plea agreement not to seek any departures ...
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