United States v. Collins, No. 15-1292 (1st Cir. 2016)
Annotate this CaseDefendant was convicted of possession with intent to distribute cocaine base. Prior to trial, Defendant moved unsuccessfully to suppress evidence found in the car in which Defendant was riding before he was arrested. After Defendant pleaded guilty, the district court sentenced Defendant as a career offender, imposing a below-guidelines sentence of 200 months. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s suppression motion, as Defendant did not failed to show he had an expectation of privacy in the evidence; and (2) the district court did not err when it sentenced Defendant as a career offender, as Defendant’s prior conviction for criminal threatening with a dangerous weapon qualified as a crime of violence under the sentencing guidelines.
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