United States v. Brooks, No. 12-3588 (8th Cir. 2013)
Annotate this CaseDefendant appealed his sentence stemming from his plea of guilty to conspiring to manufacture fifty grams or more of methamphetamine. The court affirmed the sentence, concluding that the district court did not clearly err in assessing criminal history points for two prior state convictions when it concluded that defendant was ineligible for safety-valve relief under 18 U.S.C. 3553(f); the district court did not clearly err in finding these prior offenses were not "relevant conduct" but, rather, they were "severable and distinct" from the offense of conviction; the rule of lenity did not apply in this instance; and the court rejected defendant's contention that the mandatory minimum sentence violated his right to due process.
Court Description: Criminal case - Sentencing. District court did not err in assessing criminal history points for two prior state court convictions, thereby disqualifying defendant for safety-valve sentencing; the offenses were not relevant conduct and were unrelated to the drug conspiracy for which he was convicted here; mandatory minimum sentences do not violate a defendant's due process rights.
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