United States v. Thomas, No. 17-2213 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to two counts of being a felon in possession of a firearm. The court held that defendant's prior Missouri convictions under section 195.211, RSMo 2003 and section 195.242, RSMo 2000 qualified as controlled substance offenses for purposes of calculating defendant's offense level. The court explained that, by comparison to the generic Guidelines definition, defendant's convictions under sections 195.211.3 and 195.242.1 require more than "mere words of an offer" for a sale, thus qualifying as controlled substance offenses.