Seventh Circuit - Criminal History

United States v. Wallace, 991 F.3d 810 (7th Cir. 2021). A prior sentence of “credit for 136 days previously served” was correctly assigned two criminal history points. A challenge on the grounds that the defendant did not actually serve time on the offense was “essentially a misplaced collateral attack on a state-court judgment.”

United States v. Hopper, --F.4th--, 2021 WL 3754756 (7th Cir. 2021). The court did not plainly err in assessing one criminal history point to a burglary conviction sustained after the original sentencing but before remand for resentencing.

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