What is the current state of the law on the interpretation of the criminal history of a juvenile offender?

Apparently, the district court based its upward departure on the reports of the Probation Officer and U.S. Attorney that Old Chief's serious record as a juvenile offender was not reflected in his current offender designation. An upward departure is warranted when "reliable information indicates that the criminal history category does not adequately reflect the seriousness of the defendant's past criminal conduct." See United States v. Streit, 962 F.2d 894, 903 (9th Cir. 1992). However, the district court "must specify the events in the defendant's criminal history that it believes are inadequately represented in the guidelines criminal history calculation." Id. (citing United States v. Hoyungowa, 930 F.2d 744, 747 (9th Cir. 1991)). The current record is, unfortunately, silent in this regard. ¹