US v. Keith Barnett, No. 19-4557 (4th Cir. 2022)
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A jury convicted Defendant for his role in a drug trafficking conspiracy, and the district court sentenced him to 276 months in prison. On appeal, his counsel filed a brief pursuant to Anders v. California, 386 U.S. 738 (1967), representing that Defendant has no meritorious grounds for appeal but questioning whether the district court erred by applying the Sentencing Guidelines’ two-level enhancement for maintaining a premises for the purpose of drug distribution.
The Fourth Circuit affirmed. The court concluded that the evidence supports the district court’s findings that Defendant and his coconspirator dealt drugs out of the coconspirator’s home, where they stored and packaged drugs that Defendant then sold directly outside the home and along the street. The district court, therefore, did not clearly err in applying the premises enhancement.
The court issued a subsequent related opinion or order on September 2, 2022.
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