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De Novo Review – Sentencing Guidelines

7th Circuit Court of Appeals

Case Name: United States of America v. Nathan Mansfield

Case No.: 20-2981

Officials: KANNE, BRENNAN, and KIRSCH, Circuit Judges.

Focus: De Novo Review – Sentencing Guidelines

Nathan Mansfield was convicted of possession with intent to distribute methamphetamine and sentenced to 188 months in prison. He now argues the district court erred by considering his arrest history during sentencing. But Mansfield waived this challenge when his counsel did not object to the district court’s consideration of the presentence investigation report or its contents. Even if this point was not waived, a substantial history of arrests, especially if they are similar to the offense of conviction, can be a reliable factor to consider at sentencing. We therefore conclude the district court did not err when it reviewed Mansfield’s arrest history.


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Derek A Hawkins is Corporate Counsel, at Salesforce.

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