United States v. Vanderhorst

Defendant appealed the district court's denial of his motion under Federal Rule of Criminal Procedure 36 to correct a clerical error in his Pre-Sentence Report (PSR). The Fourth Circuit held that the district court erred in holding that a defendant is categorically barred from relying on Rule 36 to correct a sentence tainted by a clerical error. However, the court nevertheless affirmed the district court's judgment because defendant's three remaining convictions were sufficient to sustain his classification and sentencing as a career offender under USSG 4B1.1. View "United States v. Vanderhorst" on Justia Law