U.S. v. Craven, No. 02-1706 (1st Cir.) (358 F.3d 11) (February 6, 2004) (Judge Jeffrey R. Howard)
Defendant's refraining from drug use and drug sales for a period of nearly two years prior to his arrest did not constitute "extraordinary rehabilitation," particularly in light of his disruptive and sometimes violent behavior while detained before sentencing. The 37-month downward departure is reversed.
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