The U.S. Supreme Court took action last month to "steer district courts to more within-guidelines sentences." The court did this by declaring that the application of Federal Sentencing Guidelines formulated after a specific crime was committed, and applied to that crime, violated the ex post facto clause of the U.S. Constitution.

Initially, the U.S. Court of Appeals for the Seventh Circuit dismissed the appeal of Marvin Peugh, convicted of five counts of bank fraud and sentenced to 70 months in prison. Peugh argued that his sentence violated the U.S. Constitution because it was based on sentencing guidelines established in 2009, though he committed the crimes in 1999 and 2000.

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