US v. Quintin Davis, No. 20-4433 (4th Cir. 2023)
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Defendant appealed from the district court’s judgment sentencing as a career offender under Sentencing Guidelines section 4B1.1(a), in that Defendant had seven prior South Carolina felony convictions supportive of such an enhancement (including, as relevant here, four South Carolina felony convictions for distribution of cocaine base). The court then sentenced Defendant to 120 months in prison for the distribution offense — plus 60 consecutive months for the firearm offense — for an aggregate prison term totaling 180 months. On appeal, Defendant pursued four challenges to his convictions and sentence.
The Fourth Circuit affirmed. The court explained that the “distribution” offense of South Carolina Code section 44- 53-375(B) does not criminalize the attempt offense of “attempted distribution,” but rather the completed offense of “attempted transfer” Accordingly, the court ruled that a section 44-53-375(B) distribution offense is not categorically disqualified from being treated as a Guidelines “controlled substance offense.” As a result of that ruling, Defendant’s contention that four of his prior drug distribution convictions — as punished by section 44-53-375(B) of the South Carolina Code — is without merit. The district court thus did not err by deeming Defendant to be a Guidelines career offender.
This opinion or order relates to an opinion or order originally issued on July 7, 2023.
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