United States v. Laboy-Nadal, No. 19-1488 (1st Cir. 2021)
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The First Circuit affirmed the sentence imposed on Defendant after he pled guilty to unlawfully possessing a machine-gun, 18 U.S.C. 922(o), and being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), holding that the sentence was reasonable.
Defendant's Guidelines Sentencing Range was sixty-three to seventy-eight months. The district judge, however, sentenced Defendant to 100 months' imprisonment and two years of supervised release. The First Circuit affirmed the sentence, holding (1) where it was ambiguous whether the district court imposed a variance or departure, any error was harmless; and (2) the court's focus on Defendant's past convictions did not take the sentence out of the range of reasonable sentences, and the court did not consider Defendant's history of drug use.
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