United States v. Harold Patrick Mitchell

TALLMAN, Circuit Judge:

Harold Mitchell appeals the 60-month sentence imposed by the District Court following his 2002 guilty plea to conspiracy to distribute, and distribution of, methamphetamine and cocaine in violation of 21 U.S.C. §§ 846 and 841(a)(1). Mitchell contends that the District Court miscalculated his criminal history score under the Federal Sentencing Guidelines by including a 1993 juvenile post-office burglary conviction that originally resulted in a term of straight probation. Because Mitchell concedes that his probation was subsequently revoked and that he was confined on…