Paul Manafort's DC plea agreement has a calculated guideline range of 17.5 to 22 years (though he can only get 10)

In this post last year following the initial indictment of Paul Manafort in DC District Court on 12 federal criminal counts, I speculated based on the amount of money allegedly involved that Manafort's guideline range, the "starting point and the initial benchmark" for his sentencing, would surely be 10+ years in federal prison.  I have just now had a chance to review a copy of Manafort's plea agreement (first discussed here), and I am intrigued to see that it confirms my (too quick) initial guideline assessment. 

The full Manafort plea agreement is available at this link, and here is the final guideline range assessment: "Based upon the total offense level and the estimated criminal history category set forth above, the Office calculates your client's estimated Sentencing Guidelines range is 210 months to 262 months' imprisonment."  But, of course, while the guidelines call for a range of 17.5+ years of imprisonment for Manafort, he is only in this agreement pleading guilty to two conspiracy counts that each carry a maximum sentence of five years in prison.  So his prison sentence for the DC case is functionally capped at 10 years (but he could get more, I believe, at his sentencing in his Virginia case where he was convicted on 8 counts following a full trial).

The reality that his guideline range is 17.5+ years but his sentence is functionally capped t 10 years makes this subsequent (boiler plate?) sentence in the Manafort plea agreement intriguing: "Based upon the information known to the Government at the time of the signing of this Agreement, the parties further agree that a sentence within the Estimated Guidelines Range (or below) would constitute a reasonable sentence in light of all of the factors set forth in 18 U.S.C. 3553(a), should such a sentence be subject to appellate review notwithstanding the appeal waiver provided below."  

Some prior related posts:

• Appreciating ugly sentencing realities facing Paul Manafort and Rick Gates after federal indictment 
• Paul Manafort has bail revoked ... and has not (yet) gotten rescued from jail by Prez Trump's clemency pen
• Paul Manafort found guilty of 8 of 18 counts ... and now faces real possibility of spending many years in federal prison
• Reported sentencing details in Paul Manafort's plea deal to wrap up his various federal prosecutions