Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. TRAVIS MONTRICE SIMS

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-24 Docket: 2:24-cr-00018-RWS-AWH-1 The eleventh-circuit vacated the defendant’s sentence and remanded the case for resentencing because the district court erroneously assigned six criminal history points for two prior sentences imposed more than fifteen years before the instant offense. The court applied U.S.S.G. § 4A1.2(e), which excludes prior sentences from the criminal history calculation unless they were imposed within fifteen years of the current offense or resulted in incarceration during that period. Because the government conceded error and the defendant was not incarcerated during the relevant fifteen-year window, the points should have been excluded. This error incorrectly increased the defendant’s criminal history category from IV to VI and raised the advisory guideline range from 121 to 151 months to 151 to 188 months. Since the district court imposed a sentence at the bottom of the incorrect range, the error was not harmless. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.