United States v. Kevin Hatch

Kevin Hatch pleaded guilty to conspiring to distribute and possess with intent to distribute 500 grams or more of methamphetamine mixture, in violation of 21 U.S.C. § 846. The district court 1 departed downward to a Category I criminal history and sentenced Hatch to the statutory minimum 120 months in prison and 5 years supervised release. On appeal Hatch argues the district court should not have assessed a criminal history point for a $75 fine he received in Nebraska for possessing drug paraphernalia. He argues, as he did below, that this offense was “similar to” the excluded offenses listed…