United States v. Dozier, No. 18-3447 (7th Cir. 2020)
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In 2017, Dozier was indicted for conspiracy and possession of methamphetamine with intent to distribute. Under the Controlled Substances Act then in effect, Dozier faced increased penalties if he had a prior conviction for a “felony drug offense,” 21 U.S.C. 841(b)(1)(A),(b)(1)(B)(viii)--a drug‐related offense “that is punishable by imprisonment for more than one year under any law of the United States or of a State.” Dozier had a 2006 conviction for unlawful possession of cocaine, a “state jail felony” punishable by imprisonment of six months to two years. In a plea bargain, the prosecutor agreed to a nine‐month sentence; Texas Penal Code 12.44(a) gives the judge discretion to punish a person convicted of a state jail felony with a period of confinement permissible for a Class A misdemeanor— a term not to exceed one year.
Dozier pleaded guilty but objected to using the 2006 conviction to enhance his sentence. The judge imposed a 20-year sentence, rejecting Dozier’s argument that the Texas conviction was not a qualifying predicate because the terms of his plea agreement exposed him to confinement of not more than one year. The Seventh Circuit affirmed. Dozier pleaded guilty to and was convicted of a two‐year state jail felony. It does not matter that the sentencing judge accepted the plea bargain and exercised the discretion conferred by state law to sentence Dozier as if he were a misdemeanant.
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