United States v. Horton, No. 11-4052 (4th Cir. 2012)
Annotate this CaseDefendant appealed his conviction for possessing a firearm while a convicted felon and the district court's imposition of a sentence of life imprisonment. The court affirmed the conviction but concluded, however, that the district court erred in applying the murder cross-reference provision in U.S.S.G. 2K2.1(c)(1) and in treating as relevant conduct a murder that occurred during the course of an unrelated and uncharged offense, which error substantially increased defendant's advisory Guidelines range. Accordingly, the court vacated the sentence and remanded for resentencing.
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