United States v. Fitch

MEMORANDUM **

James Fitch contends the district court erred by including uncounseled misdemeanor convictions to calculate his criminal history score. We agree with the district court that the convictions may be included because the record indicates that Fitch waived his right to counsel. Accordingly, we affirm.

DISCUSSION

The Sentencing Guidelines provide that certain misdemeanor convictions may be included for purposes of determining a *520defendant’s criminal history. See U.S.S.G. § 4A1.2(c). Fitch does not contest that his misdemeanor convictions qualify under § 4A1.2(c). Rather, he argues for a…