U.S. v. Easterling

Defendant appealed from his sentence for attempted robbery and possessing a firearm after sustaining a felony conviction. The guidelines in effect at the time of his sentencing assigned him two criminal history points for committing the offenses while on parole, but a retroactive amendment no longer included those points. The Seventh Circuit remanded for resentencing, finding that without the status points defendant would have a lower recommended sentencing range. (EASTERBROOK and KOLAR, concurring)