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223589P.pdf   12/06/2023  United States  v.  Jordan Cutler
   U.S. Court of Appeals Case No:  22-3589
   U.S. District Court for the Eastern District of Arkansas - Central   
   [PUBLISHED] [Kobes, Author, with Colloton and Grasz, Circuit Judges] 
   Criminal case - Sentencing. The district court did not err in assessing 
   one-criminal point under Guidelines Sec. 4A1.1(c) for a set of uncounseled 
   misdemeanor convictions as under this court's precedent, the deprivation 
   invalidates only a defendant's suspended prison sentence but not the 
   associated fines; uncounseled misdemeanor convictions with fines are valid 
   when used to enhance punishment at a subsequent conviction, and it was not 
   error to impose the point; defendant's above-guidelines sentence was not 
   substantively unreasonable.