First Circuit: Two-Level Enhancement Under § 3B1.1(c) for Leadership or Managerial Role Vacated Because Government Failed to Prove Defendant’s Order Was Actually ‘Obeyed’ by Fellow Criminal Participant by David Reutter by David M. Reutter The United States Court of Appeals for the First Circuit vacated a two-level sentencing enhancement imposed …

Texas Supreme Court: Multiple Misdemeanor Charges Resulting From Single Arrest Divisible for Expunction Purposes by Douglas Ankney by Douglas Ankney The Supreme Court of Texas held that under Article 55.01(a)(2)(A) of the Texas Code of Criminal Procedure multiple misdemeanor offenses charged in a single arrest are eligible for expunction on …