Blandin

BACKGROUND

Blandin was a resident of Clark Center, a non-secure half- way house located in Las Vegas, Nevada. In October 2004, Blandin left the center for a job interview. While away, Blandin consumed alcohol in violation of the center’s rules. Upon his return, Blandin failed an alcohol breath test and realized that his violation would require him to serve addi- tional jail time. Rather than comply, Blandin chose to escape from Clark Center, reasoning that if he was going to be sent back to jail, he wanted to at least “get some enjoyment out of the process.”

Three days after his escape, a local business owner discov- ered Blandin trespassing on his private property and called the police. Blandin claims that he voluntarily waited for officers to arrive and did not resist arrest. Although Blandin was arrested for trespassing, the trespass charge was dropped, and Blandin was instead charged with escape in violation of 18 U.S.C. § 751(a).1 Blandin subsequently pleaded guilty. Blandin’s PSR listed a base offense level of 13, and recom- mended a four-level reduction under U.S.S.G. § 2P1.1(b)(3) because Clark Center was a non-secure facility. The PSR also recommended a two-level…