of criminal history points. Then, USSG § 4A1.2, Comment (n.3), provides: Prior sentences are not considered related if they were for offenses that were separated by an intervening arrest (i.e., the defendant is arrested for the first offense prior to committing the second offense). Otherwise, prior sentences are considered related if they resulted from offenses that (A) occurred on the same occasion, (B) were part of a single common scheme or plan, or (C) were consolidated for trial or sentencing. The phrases “same occasion” and “common scheme or plan” are not defined in the Guidelines. Crimes are unrelated when they “occurred at different times, in different locations, and were committed against different victims.” United States v. Oldham, 13 Fed.Appx. 221, 226-27 (6th Cir.2001) (<HOLDING>). The phrase “common scheme or plan” is one “of
holding that rule 3702d12 does not apply to convictions for possession of firearm and carrying concealed weapon when unrelated to commission of any additional substantive offenses holding that prior felony drug convictions that fall within the conspiracy period may be used to enhance the defendants sentence if the conspiracy continued after his earlier convictions were final holding that defendants sixth amendment right to trial by a jury was not violated by district courts reliance on his prior convictions for purposes of sentencing under the acca even though convictions were neither charged in indictment nor admitted holding that all convictions under wisconsin sexual assault statute were not per se convictions for crimes of violence holding a defendants convictions for burglarizing homes within hours of each other were unrelated