United States v. Jones, No. 17-1710 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's 188 month sentence after he pleaded guilty to one count of possession with intent to distribute cocaine base. The court declined to disturb the sentence on the mere absence of a separate statement by the district court denying defendant's request for a downward departure; the underlying controlled substance offenses under the Illinois statute was not overbroad; and defendant's two prior Illinois convictions categorically qualified as controlled substance offenses under USSG 4B1.1, 4B1.2.
Court Description: Melloy, Author, with Gruender and Shepherd, Circuit Judges] Criminal case - Sentencing. The district court was fully cognizant of defendant's request for a downward departure based on overstated criminal history, as well as it authority to depart, and its decision not to will not be reversed on the mere absence of a separate statement denying the requested departure; defendant's two prior Illinois convictions for violations of 720 Ill. Comp. Stat. 570/41 categorically qualified as controlled substance offenses under Guidelines Sections 4B1.1 and 4B1.2. [ February 20, 2018
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