U.S. v. Briggins

Dist. Ct. did not err in sentencing defendant to 97-month term of incarceration on series of 2017 bank robbery charges, even though said sentence was based, in part, on Dist. Ct.’s decision to add six criminal history points to account for defendant’s 1999 convictions on 10 bank robbery charges. While defendant argued that Dist. Ct. should have added only three criminal points, since 84-month sentence he received on 1999 bank robbery charges reflected only one sentence, review of transcript of 1999 sentencing hearing revealed that sentencing judge intended to impose concurrent sentence for each of 10 robbery convictions. As such, six-point calculation for 1999 convictions was correct, since defendant received three criminal history points under section 4A1.1(a) of USSG for one 1999 bank robbery sentence and three additional criminal history points under section 4A1.1(e) for remaining nine 1999 bank robbery sentences.