United States v. Patton

MATHESON, Circuit Judge.

Jermaine Tyrell Patton was the getaway driver in a string of armed robberies that ended in his arrest. An hour after Mr. Patton's arrest, his associate shot a police detective who was investigating the pair's most recent robbery. Mr. Patton pled guilty to aiding and abetting (1) Hobbs Act robbery and (2) carrying of a firearm during the robbery. To account for the shooting, the district court increased his United States Sentencing Guidelines ("U.S.S.G." or "Guidelines") advisory sentencing range by applying (1) U.S.S.G. § 2B3.1(b)(3)(C) ("the Robbery Guideline") for…