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Cedric Patterson appealed his 57-month sentence for possession of a firearm by a convicted felon, arguing that the district court erred in applying a two-level sentencing enhancement for recklessly creating a substantial risk of harm. The appellate court affirmed, finding that Patterson was armed with a loaded weapon during a struggle with a police officer while resisting arrest in a residential area, which created a substantial risk that the firearm could accidentally discharge and harm the officer or byst
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