State v. Bryant

Defendant appeals from his convictions for second-degree assault and assaulting a public safety officer, arguing, inter alia, that the trial court erred by assigning an increased criminal history score to his conviction on Count 3 (assault of a public safety officer) based on his convictions on Counts 1 and 2 (assault in the second-degree and assault of a public safety officer, respectively), because all three counts arose out of the same criminal episode. The state concedes that the trial court erred in so doing. As explained below, we agree. Accordingly, we reverse and remand for…