Did the district court abuse its discretion by not granting a downward departure under U.S.S.G. § 4A1.3 and imposing an unreasonably long sentence based on improper weighing of 18 U.S.C. § 3553(a) factors?

QUESTIONS PRESENTED QUESTION NO. I: Whether the Sixth Circuit’s decision affirming the judgment of the district court was error, where one of predicate convictions for the careeroffender enhancement falls just within the 15-year window of consideration and his criminal-history category overrepresented his criminal record, did the district court err and abuse its discretion by not granting a downward departure under U.S.S.G. § 4A1.3? QUESTION NO. II: : Whether the Sixth Circuit’s decision affirming the judgment of the district court was : error, where the district court placed too much weight on some of the 18 U.S.C. § 3553(a) factors and too little on others, did the court err and abuse its discretion by imposing a sentence is unreasonably long? i LIST OF ALL PARTIES The caption of the case contains the names of all the