United States v. Moises Catalan

OPINION

We consider in this appeal whether a “sentence imposed” pursuant to section 2L1.2(b)(l) of the United States Sentencing Guidelines includes a probation revocation sentence served after the defendant was deported. Moisés Vasquez Catalan argues that the district court incorrectly calculated his advisory guidelines range by imposing a 16-level enhancement, rather than a 12-level enhancement, pursuant to section 2L1.2(b)(l). The Sentencing Commission recently clarified that a probation revocation sentence served after deportation should not be used to calculate the “sentence imposed” under…