Downward Departure Reversed Based on Court's Failure to Give Notice

U.S. v. Santos Munroy, 2005 WL 1406169 (6/16/05)(unpub'd) - A downward departure was reversed because the court did not give sufficient notice of its intent to depart downward. After Booker, the departure notice rules as explained in Burns v. U.S., 501 U.S. 129 (1991), still apply.