United States v. Edriss Baptiste

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Seitles & Litwin won the reversal of Mr. Baptiste’s sentence on appeal.  Mr. Baptiste was charged with fraud and sentenced in the United States District Court for the Southern District of Florida. On appeal to the Eleventh Circuit United States Court of Appeals, Seitles & Litwin argued that the district court erroneously treated a state-court sentence, imposed as a withhold of adjudication for time served in immigration custody, as a prior sentence of imprisonment of at least 60 days.  The Eleventh Circuit held that this was error, resulting in a reduction of Mr. Baptiste’s guidelines and a remand for resentencing.