United States v. Andreatti Brown

DIAZ, Circuit Judge:

Andreatti Dejohn Brown was sentenced in the U.S. District Court for the Eastern District of Virginia following his guilty plea for possession of a firearm by a convicted felon. On appeal, Brown contends that the district court erred in calculating his criminal history category. The district court added two points to Brown's criminal history score based on a prior Virginia state conviction for which Brown received a suspended sentence conditioned upon good behavior. For the reasons that follow, we affirm.

I

A

Around 2:00 a.m. on February 28, 2017, a Newport News police officer…