United States v. Lashawn P. Jiles

FLAUM, Circuit Judge.

This case presents the issue of whether a default judgment entered against a defendant constitutes a “prior sentence” for purposes of assessing criminal history points under the United States Sentencing Commission Guidelines. See USSG § 4A1.1 & .2(a) (1995). Appellant LaShawn Jiles was convicted of armed bank robbery and of using and carrying a firearm in relation to a crime of violence. At sentencing, the district court assessed the appellant criminal history points based on municipal ordinance violations for assault and battery and retail theft arising from five…