The following excerpt is from United States v. Myers, No. 13-10580 (9th Cir. 2015):
Under these circumstances, we see no reasons to deviate from our general rule that the plain-error standard governs the review of unpreserved errors. See Vonn, 535 U.S. at 73 (noting that failure to review unpreserved errors under the plain-error standard creates a perverse incentive for defendants to "simply relax and wait to see if the sentence later struck him [or her] as satisfactory"); see also United States v. Sanya, 774 F.3d 812, 815 (4th Cir. 2014) ("Because
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