United States v. Hawley

The Fourth Circuit affirmed defendant's sentence imposed after he pleaded guilt to two counts of being a felon in possession of a firearm and two counts of distributing heroin. Defendant was sentenced to 57 months in prison in part because his criminal history included a prior sentence of thirty days' imprisonment for an uncounseled misdemeanor offense. The court held that the district court properly counted defendant's prior voluntarily uncounseled misdemeanor offense, because defendant voluntarily proceeded without counsel in the prior proceeding and thus his misdemeanor conviction was constitutionally valid. View "United States v. Hawley" on Justia Law