United States v. Jones, No. 19-1644 (7th Cir. 2020)
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In 1998, Jones was convicted of two carjackings, armed bank robbery, and using firearms during those crimes of violence. His crime spree involved home invasion. He was sentenced, as a career offender under Sentencing Guideline 4B1.1, based on prior convictions for breaking and entering and armed robbery (during which Jones discharged his weapon), to 840 months in prison.
In 2018, the court vacated that sentence; Jones no longer qualified as a career offender. At resentencing, Jones’s Guidelines range was 348–390 months. The court again sentenced Jones to 840 months in prison. Considering the 18 U.S.C. 3553(a) factors, the court stated that Jones had a “history as a violent predatory individual” and the offenses were “horrific crimes of violence…. The defendant put the victims in great fear … fired the firearms in the house during one of the break-ins.” Some of that statement was inaccurate. The court stressed that Jones “would be a risk of serious criminal activity based on his prior criminal history”; Jones’s co-defendants, “with similar records [and] similar conduct,” had received sentences of 675 months and 728 months; and after his original federal sentencing, Jones received a 273-year sentence in Indiana for murder and robbery. The court reiterated its “intention … to give the statutory maximum.” The Seventh Circuit vacated. The district court did not sufficiently justify the extent of its deviation from the Guidelines.
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