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A federal appeals court has sharply criticized a judge for repeatedly ignoring the requirements of the sentencing guidelines and once again has removed him from a case.

Western District Judge John T. Elfvin showed a “pattern of behavior” that was “disturbing evidence of willfullness” by failing to state his reasons for departing from the guidelines and failing to give notice of his intention to depart, the 2nd U.S. Circuit Court of Appeals said Thursday. It was the third case in two years in which the circuit ordered reassignment from Elfvin, all three involving sentencing decisions.

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