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Escape from Custody

Jul 22, 2019

Criminal Law: Escape from Custody-Upward Variance-Substantive Reasonableness of Sentence

While awaiting transfer to county jail after violating the rules of his residential reentry center, defendant fled from custody. Defendant was subsequently apprehended and pleaded guilty to escape. The district court varied upward from the guidelines range, finding it “woefully understated” compared to defendant’s decades-long criminal history. On appeal, defendant challenged the substantive[...]

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