SWEENEY, J.
¶ 1 The question of same criminal conduct has been viewed as subject only to the abuse of discretion standard. Nonetheless, cases passing on the question appear to apply something more akin to de novo review. Here, the defendant challenges the inclusion of a number of prior convictions in his criminal history. He argues that they should have been counted as the same criminal conduct when calculating his offender score for his current sentence. We...
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