United States v. Armstrong, No. 14-2146 (8th Cir. 2015)
Annotate this CaseThe government charged Armstrong with distribution of 12.5 grams of crack cocaine, 21 U.S.C. 841(a)(1), based on Armstrong's alleged sale of crack cocaine to a confidential informant (CI) during a controlled buy that occurred in 2009. At the time of the 2009 Controlled Buy, the CI was working with the Drug Enforcement Agency and local law enforcement and had already participated in several controlled buys involving different suspected drug dealers. At trial, the government introduced substantial evidence regarding how the 2009 Controlled Buy unfolded and Armstrong's role in the buy. The district court sentenced Leslie Armstrong to 180-months' imprisonment. The Eighth Circuit affirmed, rejecting challenges to the sufficiency of the evidence, the admission of evidence of a prior (uncharged) controlled drug sale in which he was allegedly involved and that involved the same CI, and to his sentence as a career offender.
Court Description: Criminal case - Criminal law and sentencing. In a prosecution for distribution of crack, the district court did not commit a Rule 404(b) error by admitting evidence concerning an earlier, uncharged drug sale, as the government proved defendant's participation in that earlier deal by a preponderance of the evidence; the evidence was sufficient to support defendant's conviction for distribution of crack; no error in sentencing defendant as a career offender under Guidelines Sec. 4B1.1 as his 1991 and 1992 drug offenses were properly counted as separate offenses.
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