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First Circuit: Application of Subsequent Guidelines Manual to a Prior, Ungrouped Offense Violates Ex Post Facto Clause

by Douglas Ankney

The U.S. Court of Appeals for the First Circuit held that a district court violated the Ex Post Facto Clause when it applied the 2016 Guidelines Sentencing Manual to an ungrouped offense committed in 2001. This case of first impression in the First Circuit “concerns the interaction ...

 

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