United States Sentencing Commission, Guidelines Manual, § 4A1.3 (2005).

“If reliable information indicates that the defendant’s criminal history category
is substantially over-represents the seriousness of the defendant’s criminal
history or the likelihood that the defendant will commit other crimes, a
downward departure may be warranted.”

Amy Baron-Evans, Sentencing Resource Counsel, Enforcing the New Sentencing Law:
Advanced Federal Criminal Appellate Practice Seminar, March 2006.

“If the Guidelines exclude consideration that reduce the risk of recidivism, or
include factors without predictive value that increase the criminal history
score, then the criminal history rules produce sentences that are too severe.”
Id.at 18.