United States v. Ilarraza, No. 19-1395 (1st Cir. 2020)
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The First Circuit affirmed Defendant's sentence for conspiring to deal in firearms without a license and dealing in firearms without a license on a theory of aiding and abetting, holding that Defendant's challenges to his sentence were unavailing.
On appeal, Defendant argued that the district court committed several errors that inflated the calculation of his guideline sentencing range. The First Circuit disagreed, holding (1) the district court did not err in finding that Defendant was a "prohibited person" at the time of the offense; (2) the district court did not clearly err in finding that the offenses of conviction involved at least eight firearms; (3) the district court did not err in applying the exportation enhancement, the enhancement for engaging in firearms trafficking, and the role-in-the-offense enhancement; and (4) Defendant waived his claim that the district court erred in calculating his criminal history score.
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