United States v. Luis Alicea, No. 16-17545 (11th Cir. 2017)
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The Eleventh Circuit affirmed defendant's conviction after he pleaded guilty to drug and firearm offenses. The court held that the district court did not clearly err in applying a base offense level of 20 based on defendant's prior conviction of a controlled substance offense; the district court did not err in calculating defendant's criminal history score; the district court did not clearly err by finding that defendant was convicted of selling heroin on school grounds, as well as two other New York convictions; and, even if the district court did err with respect to those New
York convictions, any such error was harmless.
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