First Circuit: US v. Frates

Sentencing predicate convictions are valid, given circuit precedent.

When a non-retroactive amendment to the discretionary sentencing guidelines is adopted before a sentence becomes final on appeal, an appeals court has the prudential discretion to remand to consider the effect of the amendment, so long as the consideration would not be unduly complex and the sentencing court does not recalculate the guidelines range.

http://media.ca1.uscourts.gov/pdf.opinions/16-1933P-01A.pdf