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182537P.pdf   12/05/2019  Corey Keys  v.  United States
   U.S. Court of Appeals Case No:  18-2537
   U.S. District Court for the Southern District of Iowa - Des Moines   
[PUBLISHED] [Shepherd, Author, with Benton and Grasz, Circuit Judges] Prisoner case - Section 2255. Application Note 8 of the Guidelines regarding prior criminal conduct foreclosed Keys' sentencing argument, and the court need not determine whether the district court erred in finding it was unclear whether Keys' proffer interview supported his argument.