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United States v. Warr

ELR Citation: 38 ELR 20160
Nos. No. 07-30125, (9th Cir., 07/02/2008)

The Ninth Circuit affirmed an individual's 10-year sentence for starting nine wildland fires on National Forest Service land. The lower court did not err in calculating the advisory sentencing guidelines range when it included fire suppression costs in the loss calculation, thereby resulting in an elevated total offense level. Nor was the sentence unreasonably long. And although the lower court should have given the defendant advance notice that it would be relying on a statistical study about recidivism in young offenders during the sentencing hearing, its failure to do so did not constitute plain error.