United States v. St. Hill, No. 13-2097 (1st Cir. 2014)Annotate this Case
Appellant pled guilty to one count of distributing oxycodone. In sentencing Appellant, the district court found that other uncharged drug sales were relevant to determining Appellant’s guideline sentencing range. On appeal, Appellant argued that the district court applied both the wrong legal standard and the incorrect method of comparison in determining what uncharged drug sales were relevant to his sentence. The First Circuit affirmed on plain error review, holding that the district court did not commit plain error in its method of finding that the uncharged conduct was part of the same course of conduct as the offense of conviction.