Thursday, June 11, 2009

Attempted Escape Not a COV

US v. Harris, No, 08-1090 (10th Cir. June 10, 2009) (unpublished): Defendant gets a remand for resentencing in light of Chambers v. US, 129 S.Ct. 687 (2009) because the district court improperly concluded that his prior convictions for attempted escape under Colorado law were crimes of violence for USSG 4B1.2(a).