United States v. Roger Alan Lee

Roger Alan Lee appeals his sentence under the Sentencing Guidelines of 20 months’ imprisonment upon his conviction by guilty plea of counterfeiting obligations of the United States, in violation of 18 U.S.C. § 471. Lee argues that the district court erred in counting a sentence he received for an un-counseled misdemeanor battery conviction in determining Lee’s criminal history category because even if constitutionally valid, such convictions may not be used for sentence enhancement under Baldosar v. Illinois, 446 U.S. 222, 100 S.Ct. 1585, 64 L.Ed.2d 169 (1980). The government responds that…