James Jacob Parrish, Jr. v. United States
Environmental SocialSecurity Securities Immigration
Whether Parrish's sentence was procedurally and substantively unreasonable
QUESTIONS PRESENTED 1. Whether Parrish's sentence was procedurally and substantively unreasonable because the district court imposed an unsupported departure and/or variance? 2. Whether the district court imposed a procedurally and substantively unreasonable sentence based on the alleged variance and failure to . address Parrish's reasons for a downward departure? : 3. Whether Parrish's guideline range was incorrectly calculated because his prior conviction for North Carolina second-degree murder does not qualify as a crime of violence? ‘ : 4. iether che probation office can add a four level enhancement for , -possession of firearm and ammunition in connection with another felony offense when the defendant had not been convicted of any other. felony offense but merely charged for those felonies without each enhancement being submitted to a jury and proven beyond a reasonable doubt? How can a defendant be enhanced for a crime they have not been convicted for? Is this a violation of Sixth Amendment. due process rights ? : 5. Whether this is an ineffective assistance of-counsel . case because counsel did not inform defendant that he could be upwardly departed ; "and whether counsel's failure to .object to U.S.S.G. 2K2.1(a)(2) base _ _, offense level enhancement, eventhough appeallate attorney—did-make© -——— : those objections? Is this error plain and did this error effect his substantial rights? : . villi