N.R. SMITH, Circuit Judge:
We hold that a "Johnson waiver" in California state court has no effect on the determination of whether a defendant qualifies for a point increase under United States Sentencing Guidelines Manual § 4A1.1, Criminal History Category. A "Johnson waiver" is a unique California state court procedure, wherein the defendant voluntarily forfeits the credit for time already served in jail, so that the state sentencing court may...
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