Sixth Circuit - Criminal History

United States v. Lee, 974 F.3d 670 (6th Cir. 2020). A 23-month upward variance based on criminal history was substantively unreasonable. There was “nothing uniquely problematic about the defendant’s criminal history . . . beyond that already captured in the guidelines range,” and there was no meaningful relationship between the conviction and the defendant’s alleged likelihood of reoffending.

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