Eighth Circuit - Criminal History

United States v. Doran, 978 F.3d 1337 (8th Cir. 2020). Retroactive reclassification of a prior offense from a felony to a misdemeanor satisfies §4B1.2’s definition of a felony. If the failure to account for retroactive reclassification results in an overstated criminal history, the Guidelines permit a departure under Application Note 4 to §4B1.1.

Training Topic: