United States v. Chaires, No. 20-4162 (2d Cir. 2023)
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The United States Court of Appeals for the Second Circuit heard an appeal from Robert J. Chaires, who was challenging the procedural and substantive reasonableness of his 120-month sentence handed down by the United States District Court for the Northern District of New York. Chaires, who pleaded guilty to two counts of unlawfully distributing cocaine base, contended that the district court erred in determining his two prior state-court narcotics convictions as predicate offenses for the career offender enhancement under U.S.S.G. § 4B1.1.
The Court of Appeals agreed with Chaires and held that the district court indeed erred in its determination. The district court had based its decision on an intervening decision in United States v. Minter, which showed that Chaires's prior convictions were brought under a state provision that is categorically broader than the federal predicate definition in section 4B1.2(b). This meant that the convictions could not serve as section 4B1.1 predicate offenses, making the district court's enhancement of Chaires's Guidelines range erroneous.
Following this decision, the Court of Appeals remanded the case to the district court for resentencing.
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