United States v. Brito, ___ F.3d ___ (3d Cir. 2020). As discussed here, waiver of an argument occurs when a party intentionally relinquishes or abandons a contention, while forfeiture is the failure to assert an argument in timely fashion, without intent to give up that argument. That sometimes esoteric distinction became important in this criminal case, which involved an appeal of the sentence imposed by the District Court. Judge Bibas summarized well the outlines of this case at the outset of his opinion. “Francisco Brito, a felon, claims that he changed his ways once his daughter...