United States v. Lewis, No. 18-1916 (1st Cir. 2020)
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The First Circuit affirmed Defendant's sentence of 108 months' imprisonment for conspiracy to distribute cocaine after the district court applied a career-offender enhancement under the United States Sentencing Guidelines, holding that the district court properly applied the career-offender enhancement.
Under the Sentencing Guidelines, the career-offender enhancement applies where a defendant has at least two prior felony convictions of a "controlled substance offense." See U.S.S.G. 4B1.1(a). The commentary to section 4B1.2 provides that such offenses include conspiracies and other inchoate crimes. The district court overruled Defendant's objection to the career-offender designation, concluding that Defendant's age, conviction for conspiracy to distribute cocaine, and predicate offenses of two prior state drug-trafficking offenses triggered the career-offender enhancement. The First Circuit affirmed, holding that because this Court has previously held the commentary to section 4B1.2 authoritative in defining a "controlled substance offense," there was no clear or obvious error in Defendant's sentence.
The court issued a subsequent related opinion or order on September 4, 2020.
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