BLACK, Circuit Judge:
In August of 1995, a federal jury convicted Appellant Andy Tham of arson, mail fraud, and conspiracy to commit each of these substantive offenses. Pursuant to a cross-referencing provision contained in the arson sentencing guideline, the district court calculated Tham's sentence in accordance with the first-degree murder sentencing guideline because the arson resulted in the death of a cofelon. On appeal, Tham asserts that the district court...
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