presumptively unreasonable. Thus, in a case involving a level 18 offense committed by a category I offender, a more than minimal planning departure would be reasonable only if the sentence imposed did not exceed 41 months — the high end of the guideline range applicable to level 20 offenses committed by category I offenders. In order to justify a departure of a greater magnitude than that, the district court would have to explain why more than minimal planning should make a greater difference in the context before it than it makes under the various guidelines where it is deemed a specific offense characteristic, or else explain why the case involves aggravating factors other than a defendant’s more than minimal planning. Cf. United States v. Shuman, 902 F.2d 873, 876-77 (11th Cir.1990) (<HOLDING>). We do not suggest that this approach for
holding that defendants may agree to departure from sentencing guidelines in plea bargain holding that the degree of a departure based on conduct described as a specific offense characteristic in inapplicable guidelines was reasonable when the departure amounted to an increase in offense level no greater than that provided in the inapplicable guidelines holding that no offense alleged where affidavit described offense as felony holding that arithmetical error that resulted in an increase to a defendants base offense level pursuant to the sentencing guidelines affected his substantial rights even though the resulting sentence was within the range for the correct offense level holding that the defendants sentence was based on the career offender guidelines despite the fact that the district court calculated an offense level pursuant to the crack guidelines