United States v. Combs, No. 18-6003 (6th Cir. 2021)
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Jackson and Combs pleaded guilty to participating in a cocaine distribution ring. Jackson was sentenced to 192 months’ imprisonment due to his role as a leader in the drug-distribution conspiracy, U.S.S.G. 3B1.1(a).. Combs was sentenced to 188 months’ imprisonment due to his career-offender status, U.S.S.G. 4B1.1.
The Sixth Circuit affirmed as to Jackson, who recruited and supervised participants and held a substantial amount of the cash proceeds. The court also rejected Jackson's challenge to the mandatory-minimum 20-year sentence he received in accordance with 21 U.S.C. 841(b)(1)(A), due to his prior marijuana-trafficking conviction.
The court initially held that Combs’s Kentucky trafficking offense categorically qualified as a “controlled substance offense” under the Guidelines; U.S.S.G. 4B1.2 and Combs’s designation as a career offender. The court rejected Combs’s argument that distribution requires a commercial aspect. In an amended opinion, the Sixth Circuit cited intervening circuit precedent and reversed the career-offender finding for Combs. Conspiracy to distribute controlled substances is not a controlled substances offense under U.S.S.G. 4B1.2(b).
This opinion or order relates to an opinion or order originally issued on January 5, 2021.
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