United States v. Coast

BARKETT, Circuit Judge:

Jerome Coast appeals his seventy-month sentence imposed by the district court following his conviction for possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). In calculating the Sentencing Guidelines range, the court added two points to Coast’s criminal history for a prior conviction of driving with a suspended license, pursuant to U.S.S.G. § 4A1.2(c)(l) and § 4A1.2(k). At issue in this case is the interaction between those two provisions. 1

Under U.S.S.G. § 4A1.1 and § 4A1.2, courts calculate criminal history points by evaluating each of…