United States v. Larry Dickens

BOWMAN, Circuit Judge.

Larry Dickens pleaded guilty to two counts of distributing cocaine in violation of 21 U.S.C. § 841(a)(1), and was sentenced to thirty months in prison. The sole issue on appeal is whether the District Court 1 erred in considering a 1982 misdemeanor conviction for passing bad checks in determining Dickens’s criminal history score under the Sentencing Guidelines. We affirm.

The Sentencing Guidelines provide for an increase in the applicable sentencing range based on a defendant’s criminal history score. This score is determined by assigning a point value to prior…