United States v. Dawson, No. 20-3338 (3d Cir. 2022)
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Dawson was caught driving a car containing bags of fentanyl, stamped with the label “Peace of Mind”. Earlier that day, Police had responded to the overdose death of “L.B.”, who was found with bags of fentanyl bearing the same “Peace of Mind” label. L.B.’s cell phone revealed that Dawson had been supplying L.B. with fentanyl. Police used that phone to set up a drug deal with Dawson, apprehending him upon his arrival. Dawson pled guilty to possessing fentanyl with intent to distribute, 21 U.S.C. 841(a)(1), (b)(1)(C). Dawson was caught with only four grams of fentanyl, but he had been convicted four times of heroin trafficking under Pennsylvania law. The PSR classified him as a career offender and calculated a guidelines range of 188-235 months’ imprisonment. Dawson also objected to the PSR’s mention of L.B.’s death.
The court sentenced Dawson to 142 months’ imprisonment; it neither held that Dawson caused L.B.'s death nor deemed the issue irrelevant to crafting a sentence under the 18 U.S.C. 3553(a) factors. The Third Circuit affirmed. Dawson’s state drug trafficking convictions are career offender predicates, as the state offense, 35 Pa. Cons. Stat. §780-113(a)(30), does not criminalize a broader range of conduct than the Guidelines. Dawson did not show that his substantial rights were affected by the district court's failure to rule on whether Dawson caused L.B. to die from a drug overdose.
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