United States v. Skaggs, No. 20-4303 (4th Cir. 2022)
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Skaggs was indicted, along with 20 others, in a 39-count indictment. Two counts related to Skaggs, charging him with possessing with intent to distribute methamphetamine, 21 U.S.C. 841(a)(1); (b)(1)(C) and a related conspiracy offense, sections 841(b)(1)(A); 846. The government notified Skaggs that it intended to seek a sentencing enhancement under section 841(b)(1)(A), based on a prior “serious drug felony”: a July 2015 Virginia conviction for distributing a schedule-III controlled substance. Skaggs pleaded guilty, conceded the fact of his 2015 conviction but reserved the right to challenge whether it qualified as a “serious drug felony.” Skaggs argued that he had not “served a term of imprisonment of more than 12 months,” 21 U.S.C. 802(57)(A), although the state court sentenced him to 26 months’ imprisonment as part of six concurrent sentences.
The court concluded that Skaggs’s 2015 Virginia drug-distribution conviction was a “serious drug felony,” so his mandatory minimum on his conspiracy charge increased from 120 to 180 months and his Guidelines sentencing range increased to 180-188 months. The Fourth Circuit affirmed his 180-month sentence. Skaggs “served a term of imprisonment of more than 12 months” on his Virginia drug-distribution conviction, notwithstanding its concurrent nature, and qualified for section 841(b)(1)(A)’s enhanced mandatory-minimum sentence of 180 months.
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