United States v. Donald Dodson

KELLY, Circuit Judge.

After a jury trial, Donald Dodson was convicted of aiding and abetting embezzlement from an agency receiving federal funds, in violation of 18 U.S.C. §§ 666 and 2. At sentencing, Dodson objected to receiving a criminal history point for a previous uncounseled conviction. The district court 1 overruled the objection, but varied downward from the 18 to 24 month advisory Guidelines range and sentenced Dodson to 6 months’ imprisonment and 2 years of supervised release. Dodson appeals, renewing his objection to his criminal history calculation and challenging the sufficiency…