photographs, coupled with the evidence that many of the animals defendant shipped did not survive, may well have supported an offense level enhancement under § 5K2.0. Cf. U.S.S.G. § 5K2.2 (allowing upward departure for significant physical injury); § 5K2.3 (allowing upward departure for extreme psychological injury); § 5K2.8 (allowing upward departure for conduct that “was unusually heinous, cruel, brutal, or degrading to the victim”). Defendant's treatment of many of these endangered animals was simply reprehensible. 4 . Under § 4A1.1, the court assigns criminal history points based on the length of any “prior sentence.” Section 4A1.2(a)(1) excludes prior sentences for conduct that was "part of the instant offense.” 5 . But see United States v. Meza-Urtado, 351 F.3d 301 (7th Cir.2003) (<HOLDING>). 6 . Any mitigating information defendant
holding that the district court could consider increased sentence severity resulting from deportable alien status holding that departure based on deportable alien status was prohibited holding that deportable alien status is not a ground for departing downward holding that defendants status as a deportable alien could be considered by the district court at sentencing recognizing that district court may take into account adverse impact on incarceration caused by status as deportable alien