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Eighth Circuit: Forfeited Claim of Miscalculated Criminal History Score Is Reviewable Under Plain Error Standard

by Douglas Ankney

The U.S. Court of Appeals for the Eighth Circuit held that the forfeited claim of a miscalculated criminal-history score is reviewable for plain error.

Barthman pleaded guilty to one count of child pornography involving a prepubescent minor, in violation of 18 U.S.C. § 2252(a)(4)(B), (b)(2). He was ...

 

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