United States v. Mantha, No. 18-1951 (1st Cir. 2019)
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The First Circuit vacated the district court's sentence imposed in connection with Defendant's conviction for sexual exploitation of a child, access with intent to view child pornography, and possession of child pornography, holding that the district court erred in applying the 2016 Guidelines Sentencing Manual to two ungrouped, later-committed offenses in calculating the offense level for an offense committed in 2001.
Defendant pleaded guilty to all offenses under the same indictment, and the district court sentenced Defendant to a 196-month term of incarceration. The 2016 version of the manual, as compared to the version in effect in 2001, resulted in a high total offense level. Further, the court gave no explanation for why it chose the sentence or for why it would have done so even if it knew it was upwardly variant. The First Circuit remanded the case for resentencing, holding (1) application of the subsequent manual to the prior, ungrouped offense violated the Ex Post Facto Clause; and (2) the district court plainly erred in providing no justification for the resulting upward variance.
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