United States v. Capelton, No. 19-1613 (1st Cir. 2020)
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The First Circuit affirmed the judgment of the district court on resentencing pursuant to the 2018 First Step Act that Defendant was a career offender under section 4B1.1 of the U.S. Sentencing Guidelines, holding that Defendant failed to establish that the scope of joint venture liability under Massachusetts law is broader than under the generic standard.
In classifying Defendant as a career offender, the district court relied on two Massachusetts drug convictions. On appeal, Defendant argued that the two Massachusetts drug convictions did not qualify as predicate controlled substance offenses under the career-offender guideline. Specifically, Defendant argued (1) the convictions implicitly included what was then called joint venture liability, which was broader in scope than generic aiding and abetting liability; and (2) therefore, there could not be a categorical match between the convictions and the definition of "controlled substance offense." The First Circuit disagreed, holding (1) Defendant's contention that his two prior state convictions were over broad and did not qualify as controlled substance offenses was unavailing; and (2) the district court properly sentenced Defendant under the career-offender guideline.
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